2016 (12) TMI 545

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....t by : Shri Nitin Waghmode ORDER Per B. R. Baskaran (AM) These cross appeals are directed against the order dated 30-11-2012 passed by Ld CIT(A)-27, Mumbai and they relate to the assessment year 2009- 10. 2. The tax effect involved in the appeal filed by the revenue is less than Rs. 10.00 lakhs and hence the same is required to be dismissed in view of the Circular No.21/2015 dated 10-1....

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.... the AO came to the conclusion that certain common expenses need to be allocated to SEZ unit. Accordingly he identified certain common expenses and apportioned the same in the ratio of turnover between head office and SEZ unit. Accordingly the AO allocated a sum of Rs. 24,09,095/- to SEZ unit out of expenses booked in the Head office. The AO also allocated a further sum of Rs. 5.00 lakhs to SEZ un....

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....ng to that unit have been properly booked. He submitted that the SEZ unit was manufacturing diamond stud jewellery by purchasing readymade moulds and studding the diamonds therein. Hence the work carried on by the SEZ unit was not complicated one and hence the same did not require much of general & administrative expenses. He submitted that the books of accounts of earlier and subsequent years for....

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....d SEZ unit, the Ld CIT(A) was justified in partially confirming the addition. 8. Having heard rival submissions, we are of the view that there is merit in the contentions of the Ld D.R. It is not in dispute that both Head office and SEZ unit are under common management. Further there is interlacing of funds also. The books of accounts of both the units were maintained by the assessee only. Henc....