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2018 (12) TMI 1381

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....led by the assessee is directed against order of the CIT(A)-3, Mumbai dated 06-02-2017 and it pertains to AY 2012-13. The assessee has raised the following grounds of appeal:- "1. The Hon'ble CIT(A) has erred in confirming the order of Ld. Assessing officer by disallowing expenses to the tune of Rs. 11,26,059/- being the part of other expenses which has been debited and claimed in Profit & L....

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....,46,147. The case was selected for scrutiny and the assessment was completed u/s 143(3) of the Act, on 08-02-2015 determining total income at Rs. 50,72,210 by making addition towards disallowance of proportionate revenue expenditure claimed by the assessee for Rs. 11,26,059. 3. Aggrieved by the assessment order, assessee preferred appeal before the CIT(A). Before the CIT(A), the assessee submitte....

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....iture. Mere academic discussion is not sufficient to delete the addition made by the AO by capitalizing the expenses relatable to work-in-progress. Therefore, he opined that there is no error in allocation of other expenses to work-inprogress account and hence, upheld addition made by the AO and dismissed the appeal filed by the assessee. Aggrieved by the order of Ld.CIT(A), the assessee is in app....

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....ked other expenses on the basis of work-in-progress account to total assets and determined disallowance of Rs. 11,26,059. Neither, the assessee has furnished any details and reasons for allocating adhoc 10% of other expenses to work-in-progress account nor the AO has given any reasons for adopting the basis of capital deployment, i.e. work-in-progress ratio to the total assets' ratio to allocate o....