M/S. HELLA INDIA LIGHTING LTD.,NEW DELHI vs. DCIT, NEW DELHI
In the result, the appeal filed by the assessee is allowed for statistical purposes
ITA 1109/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jul 2019AY 2010-11
Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2010-11 Hella India Lighting Ltd., Vs Dcit, B-13, Badarpur Extension, Circle-11(1), New Delhi. New Delhi. Pan: Aaacj0101G (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Aggarwal, Advocate Revenue By : Shri Sanjay I Bara, Cit, Dr Date Of Hearing : 16.05.2019 Date Of Pronouncement : 29.07.2019 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23Rd December, 2014 Passed By The Dcit, Circle 11(1), New Delhi U/S 143(3) Read With Section 144C Of The It Act, 1961 For Assessment Year 2010-11. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing Of Automobile Components Including Head Lamps, Tail Lamps, Horns Switches, Bulbs, Sundry Lamps, Wiper Arms & Wiper Blades. It Filed Its Return Of Income On 5Th October, 2010 Declaring A Loss Of Rs.1,46,71,148/-. Since The Assessee Has Undertaken International Transactions With Its Ae, The Assessing Officer
For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Sanjay I Bara, CIT, DR
Section 143(3)Section 144CSection 40a
…new business or otherwise. 18. Aggrieved with such order of the DRP, the assessee is in appeal before the Tribunal. 19. The ld. counsel for the assessee, referring to the decision of the Hon'ble Delhi High Court in the case of Indo Rama Synthetics vs. CIT, 333 ITR 18, submitted that the Hon'ble High Court in the said decision held that the project related expenses are revenue in nature when an amount is spent for expansion of business and such expansion was abandoned, the amount spent shall be allowed as revenue expenditure. 20. The ld. DR, on the other hand, relied on the order of the A.O./TPO/DR. 21. We ha…