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    <title>2015 (4) TMI 715 - ITAT BANGALORE</title>
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    <description>Additional evidence admitted at the appellate stage, including a revised TDS return, cannot be relied on to delete a disallowance under section 40(a)(ia) unless the Assessing Officer is given a reasonable opportunity to examine and rebut it under rule 46A. Expenditure of a grant to milk producers&#039; co-operative societies for construction of buildings was treated as revenue in nature because it was incurred under the society&#039;s bye-laws and board approval to facilitate milk collection and testing, without creation of any capital asset in the assessee&#039;s hands. The procedural disallowance issue was restored for fresh examination, while the revenue character of the building grants was upheld.</description>
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    <pubDate>Fri, 25 Oct 2013 00:00:00 +0530</pubDate>
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      <title>2015 (4) TMI 715 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=258834</link>
      <description>Additional evidence admitted at the appellate stage, including a revised TDS return, cannot be relied on to delete a disallowance under section 40(a)(ia) unless the Assessing Officer is given a reasonable opportunity to examine and rebut it under rule 46A. Expenditure of a grant to milk producers&#039; co-operative societies for construction of buildings was treated as revenue in nature because it was incurred under the society&#039;s bye-laws and board approval to facilitate milk collection and testing, without creation of any capital asset in the assessee&#039;s hands. The procedural disallowance issue was restored for fresh examination, while the revenue character of the building grants was upheld.</description>
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      <pubDate>Fri, 25 Oct 2013 00:00:00 +0530</pubDate>
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