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1,569 results for “TDS”+ Section 37clear

Sorted by relevance

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Key Topics

Section 143(3)72Addition to Income56Disallowance53Section 14A48Section 153C40Deduction39Section 4034TDS30Section 25029Section 201(1)

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2561/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Nov 2023AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

section 37 of the Act merely by 37 of the Act merely by virtue of its being allowable u/s 35(2AB). Further, virtue of its being allowable u/s 35(2AB). Further, if the expenses are liable for TDS

Showing 1–20 of 1,569 · Page 1 of 79

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Section 6826
Section 143(1)25

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2558/MUM/2023[2014-2015]Status: DisposedITAT Mumbai28 Nov 2023AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

section 37 of the Act merely by 37 of the Act merely by virtue of its being allowable u/s 35(2AB). Further, virtue of its being allowable u/s 35(2AB). Further, if the expenses are liable for TDS

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2559/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Nov 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

section 37 of the Act merely by 37 of the Act merely by virtue of its being allowable u/s 35(2AB). Further, virtue of its being allowable u/s 35(2AB). Further, if the expenses are liable for TDS

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2560/MUM/2023[2016-2017]Status: DisposedITAT Mumbai28 Nov 2023AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

section 37 of the Act merely by 37 of the Act merely by virtue of its being allowable u/s 35(2AB). Further, virtue of its being allowable u/s 35(2AB). Further, if the expenses are liable for TDS

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2562/MUM/2023[2018-2019]Status: DisposedITAT Mumbai28 Nov 2023AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

section 37 of the Act merely by 37 of the Act merely by virtue of its being allowable u/s 35(2AB). Further, virtue of its being allowable u/s 35(2AB). Further, if the expenses are liable for TDS

ACIT 14 (1)(2), MUMBAI, MUMBAI vs. SHRIRAM CHITS MAHARASTRA LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 66/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jun 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

For Appellant: Mr. Raghav MenonFor Respondent: Mr. Ashok Kumar Ambastha, Sr. DR
Section 37(1)

37 of the Act and non the Act and non- allowable expenditure as per section 40, 43B. allowable expenditure as per section 40, 43B. The same are applicable for claiming the interest paid on late applicable for claiming the interest paid on late remittance of TDS

DENTSU AEGIS NETWORK INDIA PRIVATE LIMITED(ERSTWHILE VIZEUM MEDIA SERVICE INDIA MERGED IN DAN INDIA),MUMBAI vs. INCOME TAX OFFICER, CIRCLE 8(3)(2), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6122/MUM/2025[2014-15]Status: DisposedITAT Mumbai20 Feb 2026AY 2014-15

Bench: Shri Rahul Chaudhary & Shri Makarand Vasant Mahadeokardentsu Aegis Network Dcit Central India Private Limited Circle-1(1), (Erstwhile Vizeum Media Vs. Aayakar Bhavan, Service India Merged Maharashi Karve With Dentsu Aegis Marg, Mumbai-400 Network India Private 020 Limited W.E.F. 1St April 2017) 2Nd Floor, Devchand House, Dr. A. B. Road, Shiv Sagar Estate Mumbai, Worli So, Mumbai-400 018 Pan/Gir No. Aahca3058N (Applicant) (Respondent) Assessee By Shri Ketan Ved & Shri Abdul Kadir Jawadwala, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 02.02.2026 Date Of Pronouncement 20.02.2026

Section 142(1)Section 143(3)Section 250Section 37(1)Section 40Section 40A(2)(b)

TDS should not be deducted on reimbursements, which itself showed that the assessee’s contention that these were pure reimbursements was not acceptable. He thus concluded that the reimbursement of salary and bonus was not allowable as business expenditure and disallowed the same under section 37

STRIDES PHARMA SCIENCE LIMITED,MUMBAI vs. INCOME TAX OFFICER, 15(3)(2),, MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 5721/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Mar 2025AY 2020-21
For Appellant: \nShri Nishit GandhiFor Respondent: \nMr. R. A. Dhyani
Section 143(3)Section 144Section 14ASection 250Section 35Section 37(1)

37(1) of\nthe Act, they are specifically excluded in clarification issued. There is no restriction\non an expenditure being claimed under above sections to be exempt, as long as it\nsatisfies necessary conditions under section 30 to 36 of the Act, for computing income\nunder the head, \"Income from Business and Profession\".\n16. For claiming benefit under section

BALRAJSINGH JAGJITSINGH KHARBANDA,MUMBAI vs. ADIT, CPC , BANGALORE

In the result, appeal of the assessee is In the result, appeal of the assessee is dismissed dismissed

ITA 797/MUM/2023[2019-20]Status: DisposedITAT Mumbai07 Jun 2023AY 2019-20

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2019-2020 Balrajsinghjagjitsingh Adit, Cpc Bangalore, Kharbanda, Cpc, Bangalore-560500. C/3, Ravi Darshan, Sherly Vs. Rajan Road, Bandra West, Mumbai-400050. Pan No. Adhpk 1733 G Appellant Respondent Assessee By : Mr. Rajesh S. Kothari Revenue By : Kamble Minal Mohan, Dr : Date Of Hearing 05/06/2023 : Date Of Pronouncement 07/06/2023 Order

For Appellant: Mr. Rajesh S. KothariFor Respondent: Kamble Minal Mohan, DR
Section 0Section 143(1)Section 143(1)(a)

section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or (vi) addition of income appearing in Form 26AS or Form 16A or (vi) addition of income appearing in Form 26AS or Form 16A or Form16 which has not been included in computing the tota Form16 which has not been included in computing the tota Form16

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1, THANE, ASHAR IT PART, WAGLE INDUSTRIAL ESTATE, THANE WEST vs. MAHYCO MONSANTO BIOTECH (INDIA) PRIVATE LIMITED, SANDOZBAUGH SO THANE

In the result, the Cross appeal of the assessee is partly allowed

ITA 3325/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Nov 2024AY 2017-18
Section 143(3)Section 43B

37(1) of the Act, they are specifically\nexcluded in clarification issued. There is no restriction on an expenditure being claimed under above\nsections to be exempt, as long as it satisfies necessary conditions under section 30 to 36 of the Act, for\ncomputing income under the head, \"Income from Business and Profession\".\n16. For claiming benefit under section

JOINT COMMISSIONER OF INCOME TAX (OSD)-I/C DCIT CIRCLE 8(3)(1), MUMBAI vs. M/S TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

ITA 1835/MUM/2023[2017-2018]Status: DisposedITAT Mumbai30 Oct 2024AY 2017-2018
For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Biswanath Das, CIT DR
Section 10(15)(iv)Section 101A(7)Section 143(3)Section 32Section 37(1)Section 40Section 43BSection 44

37(1) of the Income Tax Act, 1961, when the same was in violation of section 101A(7) r.w.s. 2(9) of the Insurance Act?\"\nc) \"Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred by upholding that the provisions of section 40(a)(i) of the Income

JCIT(OSD) CIRCLE 2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

ITA 2258/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21
Section 143(3)Section 144Section 14A

Section 37(1) of the Act. In the case of\nFortune Park Hotels Ltd. 159 taxmann.com 1217 (Delhi\nTrib.), the Delhi ITAT held that ESOP expenses are allowable as per\nESOP scheme and further such expenses had been duly taxed in hands\nof employees as \"perquisites\" and included in Form-16 of employees\nand due TDS

GOLDMAN SACHS (INDIA) FINANCE PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NEW DELHI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025
For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

section 37 of the Act\nwhich lacks basis and is contrary to law.\n6. Ground No. 6: Short-grant of TDS

ACIT-6(1)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA SUN LIFE AMC LTD., MUMBAI

In the result, the appeal by the Revenue is partly allowed

ITA 792/MUM/2025[2020-21]Status: DisposedITAT Mumbai08 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailaditya Birla Sun Life Amc Ltd., Tower 1, Jupiter Mill Compound, 17Th Floor, One World Center, 841, Senapati Bapat Marg, ............... Appellant Mumbai - 400013 Pan : Aaacb6134D V/S

For Appellant: Shri Ronak DoshiFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 40

TDS within the due date. On the other hand, the assessee is claiming the amount in this year. Accordingly, the AO held that the amount of ₹ 65,03,040/- is not allowable as a deduction in the year under consideration. 8. The learned CIT(A), vide impugned order, dismissed the ground raised by the assessee on this issue and held

JAMNADAS VIRJI SHARES AND STOCK BROKERS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 4(3)(1), MUMBAI

ITA 8363/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17
Section 10(34)Section 133ASection 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

TDS, although appearing in Form 26AS\nand granted credit for in the intimation under section 143(1).\n13. The AO erred in levying interest under section 234A of Rs.\n1,770/-/- and CIT(A) erred in confirming the same.\n14. The AO erred in levying interest under section 234B of Rs.\n26,928/- and under section 234C

ACIT 15(3)(1), MUMBAI vs. THYROCARE TECHNOLOGIES LIMITED, NAVI MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 6723/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Mar 2026AY 2020-21

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 7292/Mum/2025 (Assessment Year: 2022-23) (Assessment Year: 2021-22) Ita No. 6721/Mum/2025 Ita No. 7293/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2023-24) Assistant Commissioner Of Income Tax – 15(3)(1), Room No.460, 4Th Floor, Aaykar Bhavan, M.K. Road, ............... Appellant Mumbai – 400020 Pan : Aabct2577P V/S Thyrocare Technologies Limited, ……………… Respondent D/37, 1 Ttc Industrial Area, Midc, Turbhe, Navi Mumbai - 400703

For Appellant: Shri M. SubramaniamFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 142(1)Section 143(2)Section 14ASection 250Section 37(1)

section 37(1) of the Act. 17. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings, from the perusal of the profit and loss account of the assessee, it was observed that the assessee has claimed an expenditure of Rs. 17.49 crore as sales incentive. Accordingly, the assessee was asked

ASSISTANT COMMISSIONER OF INCOME TAX-15(3)(1), MUMBAI, MUMBAI vs. M/S THYROCARE TECHNOLOGIES LIMITED, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 7293/MUM/2025[2023-24]Status: DisposedITAT Mumbai30 Mar 2026AY 2023-24

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 7292/Mum/2025 (Assessment Year: 2022-23) (Assessment Year: 2021-22) Ita No. 6721/Mum/2025 Ita No. 7293/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2023-24) Assistant Commissioner Of Income Tax – 15(3)(1), Room No.460, 4Th Floor, Aaykar Bhavan, M.K. Road, ............... Appellant Mumbai – 400020 Pan : Aabct2577P V/S Thyrocare Technologies Limited, ……………… Respondent D/37, 1 Ttc Industrial Area, Midc, Turbhe, Navi Mumbai - 400703

For Appellant: Shri M. SubramaniamFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 142(1)Section 143(2)Section 14ASection 250Section 37(1)

section 37(1) of the Act. 17. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings, from the perusal of the profit and loss account of the assessee, it was observed that the assessee has claimed an expenditure of Rs. 17.49 crore as sales incentive. Accordingly, the assessee was asked

ASSISTANT COMMISSIONER OF INCOME TAX-15(3)(1), MUMBAI, MUMBAI vs. M/S THYROCARE TECHNOLOGIES LIMITED, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 7292/MUM/2025[2021-22]Status: DisposedITAT Mumbai30 Mar 2026AY 2021-22

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 7292/Mum/2025 (Assessment Year: 2022-23) (Assessment Year: 2021-22) Ita No. 6721/Mum/2025 Ita No. 7293/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2023-24) Assistant Commissioner Of Income Tax – 15(3)(1), Room No.460, 4Th Floor, Aaykar Bhavan, M.K. Road, ............... Appellant Mumbai – 400020 Pan : Aabct2577P V/S Thyrocare Technologies Limited, ……………… Respondent D/37, 1 Ttc Industrial Area, Midc, Turbhe, Navi Mumbai - 400703

For Appellant: Shri M. SubramaniamFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 142(1)Section 143(2)Section 14ASection 250Section 37(1)

section 37(1) of the Act. 17. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings, from the perusal of the profit and loss account of the assessee, it was observed that the assessee has claimed an expenditure of Rs. 17.49 crore as sales incentive. Accordingly, the assessee was asked

ACIT 15(3)(1), MUMBAI vs. THYROCARE TECHNOLOGIES LIMITED, NAVI MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 6721/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 7292/Mum/2025 (Assessment Year: 2022-23) (Assessment Year: 2021-22) Ita No. 6721/Mum/2025 Ita No. 7293/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2023-24) Assistant Commissioner Of Income Tax – 15(3)(1), Room No.460, 4Th Floor, Aaykar Bhavan, M.K. Road, ............... Appellant Mumbai – 400020 Pan : Aabct2577P V/S Thyrocare Technologies Limited, ……………… Respondent D/37, 1 Ttc Industrial Area, Midc, Turbhe, Navi Mumbai - 400703

For Appellant: Shri M. SubramaniamFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 142(1)Section 143(2)Section 14ASection 250Section 37(1)

section 37(1) of the Act. 17. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings, from the perusal of the profit and loss account of the assessee, it was observed that the assessee has claimed an expenditure of Rs. 17.49 crore as sales incentive. Accordingly, the assessee was asked

ACIT 15(3)(1), MUMBAI vs. THYROCARE TECHNOLOGIES LIMITED, NAVI MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 6715/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Mar 2026AY 2022-23

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 7292/Mum/2025 (Assessment Year: 2022-23) (Assessment Year: 2021-22) Ita No. 6721/Mum/2025 Ita No. 7293/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2023-24) Assistant Commissioner Of Income Tax – 15(3)(1), Room No.460, 4Th Floor, Aaykar Bhavan, M.K. Road, ............... Appellant Mumbai – 400020 Pan : Aabct2577P V/S Thyrocare Technologies Limited, ……………… Respondent D/37, 1 Ttc Industrial Area, Midc, Turbhe, Navi Mumbai - 400703

For Appellant: Shri M. SubramaniamFor Respondent: Shri Hemanshu Joshi, Sr.DR
Section 142(1)Section 143(2)Section 14ASection 250Section 37(1)

section 37(1) of the Act. 17. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings, from the perusal of the profit and loss account of the assessee, it was observed that the assessee has claimed an expenditure of Rs. 17.49 crore as sales incentive. Accordingly, the assessee was asked