2019 (3) TMI 1168

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....sp; P.C. This appeal is filed by the Revenue to challenge the judgement of the Income Tax Appellate Tribunal. Following question is presented for our consideration:- "Whether, on the facts and in the circumstances of the case and in law, the Tribunal is justified in deleting the addition of Rs. 6,71,11,494/- on account of adjustment of the ratio for allocation of administrative and other ....

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....ivity other than the tonnage tax business, common costs and attributable to the tonnage tax business shall be determined on a reasonable basis. (2) Where any asset, other than a qualifying ship, is not exclusively used for the tonnage tax business by the tonnage tax company, depreciation on such asset shall be allocated between its tonnage tax business and other business on a fair proportion to....

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....ed under four different heads of Rs. 45.20 Crores in the ratio of 67:33 by following "Annualised Operating Charter Hire Income Method". The A.O.rejected the system adopted by the assessee only in respect of administrative expenses. By applying direct income proportionate method, the A.O. allocated the administrative expenses to the extent of 73.06 % to the tonnage tax activity and rest 26.94 % to ....