TaxTMI 
TaxTMI 
2021 (1) TMI 786
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....ged in the business of manufacturing of cement, sugar and generation of power, filed its return of income offering income of Rs. 22,45,34,958/-. For the relevant A.Y, the assessee had returned a gross total income of Rs. 32,63,02,708/- and claimed a deduction of Rs. 10,07,52,120/- u/s 80IA in respect of its power division. During the assessment proceedings u/s 143(3) of the Act, the AO disallowed the cost of steam considered as nil value and denied deduction u/s 80IA in respect of the power division due to which in the Sugar Division, the expenditure towards the cost of steam purchased from power division was also disallowed. The matter travelled upto ITAT and the ITAT allowed deduction u/s 80IA. However, it held that the cost of steam for ....
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..../2014 with regard to steam. 2. Your Appellant submits that the CIT(A) as well as the Assessing Officer ought to have considered the actual quantity and value of steam supplied to sugar division instead of reworking the same. 3. Your Appellant submits that the CIT(A) ought not to have confirmed the working of the Assessing Officer, which is not scientific method of calculation, as compared to the actuals submitted, therefore the Assessing Officers working may be deleted. 4. The CIT(A) ought to have considered the submission of your Appellant during the appellate proceeding would have appreciated the mistake in quantity and value worked out by the Assessing Officer, thereby would have directed to accept the working of your appellant. ....
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....ny consequential affect in the subsequent A.Ys, the learned Counsel for the assessee submitted that in the subsequent years, there was no disallowance and these calculations would not in any way affect the computation of income in the subsequent years. Since the relief granted by the Add. CIT u/s 154, was more than the relief claimed by the assessee in its application u/s 154 of the Act, we do not see any prejudice being caused to the assessee. In view of this, we do not see any reason to interfere with the order of the Add. CIT dated 11.8.2014 u/s 154 of the Act. 6. In the result, assessee's appeal in ITA No.1446/Hyd/ 2017 is dismissed. ITA No.2138/Hyd/2017 7. This is assessee's appeal for the A.Y 2009-10 against the order of the CIT(A)....
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....Your Appellant submits that there is no concealment of income or furnishing of inaccurate particulars as the assessing Officer reworked the cost of steam on mere assumption and presumption. 3. Your Appellant submits that the calculation regarding cost of steam submitted is as per the records and on scientific method, there is no mistake in the valuation of steam as well as quantity of steam consumed by the sugar division from the power division. Hence there is no concealment of income or furnishing of inaccurate particulars. 4. The CIT(A) as well as the Assessing Officer having accepted the consistent method of arriving at cost of steam in the past, ought to have accepted the same for the year under consideration, therefore there is no ....