https://www.taxtmi.com/caselaws?id=764750 ITAT Ahmedabad allowed the assessee's appeal for statistical purposes in a penalty case under Section 270A regarding allocation of 10% administrative expenses to 80-IA unit. The CIT(A) failed to consider the assessee's submissions in Form No. 35 highlighting substantial relief granted in quantum proceedings and grounds of appeal arguing that penalty was not leviable for ad-hoc expense apportionment. Since CIT(A) did not discuss case facts or appeal grounds, the matter was remanded for fresh consideration. en-us Wed, 15 Jan 2025 00:00:00 +0530 Fri, 17 Jan 2025 08:45:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764750 ITAT Ahmedabad allowed the assessee's appeal for statistical purposes in a penalty case under Section 270A regarding allocation of 10% administrative expenses to 80-IA unit. The CIT(A) failed to consider the assessee's submissions in Form No. 35 highlighting substantial relief granted in quantum proceedings and grounds of appeal arguing that penalty was not leviable for ad-hoc expense apportionment. Since CIT(A) did not discuss case facts or appeal grounds, the matter was remanded for fresh consideration. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764750