2016 (11) TMI 1669

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.... Shri M. Viswanathan, CA Respondent by:  Shri Supriyo Pal, JCIT   ORDER N.R.S. Ganesan, Both the appeals of the assessee are directed against the respective orders of the Commissioner of Income Tax (Appeals)-6, Chennai, dated 16.12.2015 and pertain to assessment years 200910 and 2012-13.  We heard both the appeals together and disposing of the same by this common or....

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....ch, how the construction of compound wall is treated as a temporary expenditure by the assessee?  The Ld. representative submitted that it is not only a construction of compound wall, underground sewage drain was also constructed temporarily and temporary godown for keeping the cables was also constructed.  Therefore, according to the Ld. representative, the assessee is entitled for allo....

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....on either side and perused the relevant material available on record.  Admittedly, the assessee incurred expenditure for construction of compound wall, watch tower, godown, underground drainage, etc.  This Tribunal is of the considered opinion that the assessee has constructed compound wall, sewage drain, godown, etc. for permanent use in the business.  It cannot be said that the in....

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....d and third limbs of Rule 8D(2).  According to the Ld. representative, the Assessing Officer has to restrict himself only to the income earned by the assessee.  Therefore, the disallowance made by the Assessing Officer beyond the income earned by the assessee is not justified.      8. We have heard Shri Supriyo Pal, the Ld. Departmental Representative also.  T....