Bench: us, the error noted in the assessment order passed in the case of the assessee under Section 143(3) of the Act for the impugned year i.e. AY 2017-18 was that the assessee’s claim of deduction for creation of special reserve from the profit of “eligible business” as per Section 36(1)(viii) of the Act had been allowed in excess by the Assessing Officer without properly examining the calculation of the claim submitted by the assessee.
43D of the Act to its business of long term finance, further, it has contended in para 2.3 that the apportionment of cost to the Income centers should be based on foots and reasons as also on equitable and scientific basis. Having stated that, the assessee bank Summarily allocated the Indirect cost in the ratio