RAJPAL YADAV, P.M.JAGTAP
Akzo Nobel Car Refinishes India (P. ) Ltd. – Appellant
Versus
Deputy Commissioner of Income-tax, Circle 1(2), New Delhi – Respondent
Rajpal Yadav, Judicial Member. - The present two appeals are directed at the instance of assessee against the orders of learned CIT (Appeals) dated 17-9-2002 and 30-9-2002 passed in assessment years 1998-99 and 1999-2000. One of the issues in both the years is common and, therefore, we heard both appeals together and deem it appropriate to dispose of them by this common order.
2. The first grievance in assessment year 1998-99 is that learned CIT(Appeals) has erred in confirming the disallowance of Rs. 26,94,550.
3. The brief facts of the case are that assessee is a private limited company, incorporated on 5-12-1997. It filed its return of income on 27-11-1998 declaring total loss of Rs. 26,94,550, for the accounting period 5-12-1997 to 31-3-1998. The learned Assessing Officer on scrutiny account, found that in the computation of loss filed by the assessee in return of income, it has shown loss from business to be carried forward at Rs. 6,51,743. According to the Assessing Officer, there are certain ambiguity and errors in the computation. Anyway, the facts relevant for the present dispute are that the assessee had incurred expenses of Rs. 26,56,199 which it claimed as revenue ex
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