Assistant Commissioner of Income-Tax vs. Laxmi Civil Engineering Services Pvt. Ltd., Kolhapur
In the result, the appeal of the Revenue in ITA No
ITA 1247/PUN/2015[2011-12]Status: DisposedITAT Pune26 Jun 2020AY 2011-12
Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.
For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)
…on the series of the decisions such as : (i) Control Touch Electronic Pvt. Ltd., 77 ITD 522; (ii) CIT vs. Suman Papers & Boards Ltd., 314 ITR 119; (iii) JK Export SB of Settlement Commission, SA No.21 dt. 29.01.1996; and, (iv) CIT vs. V. Subramaniyan (Late), 305 ITR 289. 9. The summary of the assessee’s explanation in this regard is extracted as under :- “The Business facilitation expenses are sourced by inflating various expenses debited to Profit & Loss A/c. When source of income is generated from the profit & loss a/c it is nothing but income from business. Therefore, it is eligible for deduction U/s. 80IA(4)…