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Income Tax Appellate Tribunal, PANAJI ‘SMC’ BENCH : PANAJI
Before: SHRI SATBEER SINGH GODARA
ORDER These assessee’s twin appeals for assessment years 2011-12 & 2012-13, arise against the CIT(A), Belagavi’s separate orders, both dated 18.06.2018, passed in case ITA.No.04/BGV/2016-17 and in case No.339/BGM/2014-15, in proceedings u/s. 143(3) r.w.s. 147 of the Income Tax Act, 2 ITA.No.403 & 404/PAN/2018 1961 and in proceedings u/s. 143(3) of the Income Tax Act, 1961, (in short "the Act") assessment year-wise, respectively.
Heard both the parties. Case file perused.
It emerges during the course of hearing that the assessee’s identical sole substantive grievance raised in both these appeals seeks to reverse the learned lower authorities action adding interest income of Rs.3,18,602/- and Rs.11,71,029/- [received on term deposits] during the course of assessment and upheld in the CIT(A)'s order(s) as follows :
3 ITA.No.403 & 404/PAN/2018 3. I have given my thoughtful consideration to vehement rival stands and find no merit in the assessee’s arguments. This is for the precise reason in light of the CIT(A)'s detailed discussion extracted in the preceding paragraph that the impugned deduction for preliminary and pre-operative expenses prior to commencement of the assessee’s business could hardly be given to be set-off against any other income. Learned CIT(A) has already concluded that the assessee could very well amortize or capitalize the impugned expenditure since it had not even commenced its manufacturing activities in both these financial years. Faced with the situation, I find no merit in assessee’s instant substantive ground. The same is rejected therefore. Ordered accordingly.
These assessee’s twin appeals are dismissed in above terms. A copy of this common order be placed in the respective case files.
Order pronounced in the open court on 25.01.2023.