IN THE INCOME TAX APPELLATE TRIBUNAL “B BENCH KOLKATA BEFORE SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER Assessment Year: 2017-18 M/s. La Opala RG Ltd. DCIT, Circle-11(1) (formerly

8th Floor, Premises No.803 & Circle-12(1), Kolkata)

Vs.

804 Eco Centre EM-4, Sector-V, Kolkata-91.

(PAN: AAACL5569J)

(Appellant) (Respondent)

Present for:

Appellant by : Shri A. K. Tulsyan, FCA Respondent by : Smt. Monalisha Pal Mukherjee, JCIT, Sr. DR Date of Hearing : 30.04.2025 Date of Pronouncement : 06.05.2025

O R D E R

Per Sanjay Awasthi, Accountant Member :

The present appeal emanates from order passed u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) on 31.07.2024 by Ld. CIT(A), NFAC, Delhi.

1.1. It is seen that on the two issues surviving for adjudication at the second appellate stage (i.e. allocation of common expenses between the four units; and allowing the claim of duty draw back etc. for relief u/s. 80IC of the Act), the Ld. Assessing Officer has given a detailed finding, which may be briefly summarized. Regarding the issue of allocation of common expenses between the eligible unit (Sitarganj in Uttarakhand) and other three units els