THE PR. COMMISSIONER OF INCOME TAX vs. M/S CISCO SYSTEMS
The appeals are allowed; the impugned
ITA/27/2019HC Karnataka18 Jun 2021
Bench: SATISH CHANDRA SHARMA,R. NATARAJ
Section 143(3)Section 144Section 260ASection 263Section 32
1A) [***]
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(2) Where, in the assessment of the assessee, full effect
cannot be given to any allowance under sub-section (1) in
any previous year, owing to there being no profits or gains
chargeable for that previous year, or owing to the profits or
gains chargeable being less than the allowance, then, subject
to the provisions of sub-section