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The Tax PublishersITA No. 454/Jp/2019
2021 TaxPub(DT) 0218 (Jp-Trib)INCOME TAX ACT, 1961
Section 10AA
Expenditure to the extent of 25% of purchases held as non-genuine and disallowed by the AO related to the same business activity of manufacture and export in respect of which assessee was held eligible for deduction under section 10AA. Therefore, deduction under section 10AA was to be allowed on the enhanced profits in light of accepted legal position by CBDT Circular No. 37/2016, dated 2-11-2016.
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Deduction under section 10AA - Allowability - Profits enhanced on account of addition under section 69C disallowing 25% of alleged unverifiable purchases -
AO made addition under section 69C by disallowing 25% of alleged unverifiable purchases and denied deduction under section 10AA as regards the amount so added. Held: Expenditure to the extent of 25% of purchases held as non-genuine and disallowed by the AO related to the same business activity of manufacture and export in respect of which assessee was held eligible for deduction under section 10AA. Therefore, deduction under section 10AA was to be allowed on the enhanced profits in light of accepted legal position by CBDT Circular No. 37/2016, dated 2-11-2016.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
IN THE ITAT, JAIPUR BENCH
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