2019 (2) TMI 1442

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....PDS Legal ORDER P.C. 1. This Appeal under Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 14th December, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). This appeal relates to Assessment Year 200607. 2. The Revenue urges the following substantial questions of law for our consideration : "(i) Whether on the facts and in the circumstances of the c....

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....nt assessee. It also notes the binding order of this Court dated 5th August, 2011 in CIT Vs. M/s. Monsanto India Ltd. (Income Tax Appeal No.633 of 2010 and other connected appeals) raising the same issue, which were dismissed by this Court. (b) Therefore, as the impugned order has followed the decision of this Court, no fault can be found with the same. This in the absence of the Revenue pointing....

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....rlier assessment year i.e. A.Y. 200405, the Assessing Officer himself under Section 143(3) of the Act allocated the common corporate expenses at 10% between the two 80IB units. In the above view, the impugned order of the Tribunal concluded that as the respondent has provided a scientific basis for allocation of expenses and therefore disregarded the allocation of expenses on the basis of turnove....