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O.K.NARAYANAN, SUSHMA CHOWLA
Joint Commissioner of Income-tax, SR-27 (Mumbai) – Appellant
Versus
Essar Shipping Ltd. – Respondent
Per Dr. O.K. Narayanan, Accountant Member. - This appeal is filed by the revenue. The relevant assessment year is 1996-97. The appeal is directed against the order passed by the CIT(A)-I at Chennai on 20-11-1999 and arises out of the assessment completed under section 143(3) of the Income-tax Act, 1961.
2. The assessee is a shipping company. The assessee-company had filed its return of income for the impugned assessment year declaring NIL income. The positive income was set off against the brought forward loss of the preceding assessment years. The return of income filed by the assessee-company was initially processed under section 143(1)(a) with certain prima facie adjustments having been made. Thereafter, the case was selected for scrutiny and the assessment was completed under section 143(3) of the Act.
3. In the course of assessment proceedings, among other things, the Assessing Officer has stressed on two items. The first item is that of the incidental expenses incurred by the assessee-company in selling four ships out of its fleet during the previous year relevant to the assessment year under appeal. The assessee-company had sold four ships during the relevant previous yea
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