ORDER

Per C.M.Garg,JM

This is an appeal filed by the assessee against the order of the CIT(A),1, Bhubaneswar dated 25.8.2017 for the assessment year 2013-14.

2. The assessee has raised following grounds of appeal:

“1. On the facts and in law, ld CIT(A) erred in not adjudicating on the ground that the appellant has not commenced commercial operations. The ld CIT(A) failed to appreciate that the entire income and expenses for the year under consideration should be treated as capital in nature.

2. Without prejudice to the ground No.1, on the facts and in the circumstances of the case and in law, the ld CIT(A) erred in confirming the disallowance of Rs.1,33,97,073/- received by the appellant from Dubai Almn. Company Ltd., towards advance against equity by treating the same as revenue in nature, only on the ground that the appellant has credited the same to P&L account.”

3. Facts in brief of the case are like this. During the course of assessment proceedings, the Assessing Officer noticed that the assessee has shown total income of Rs.1,33,97,073/- after adding back the pre- operative expenses of Rs.4,88,603/-. Against the total income arrived at, the assessee has reduced the same amount i.e.