2021 (4) TMI 766

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....eal by the Revenue is directed against order of learned CIT appeal dated 20.11.2018 and pertains to A.Y. 2010-11. 2. The grounds of appeal read as under :- 1. The CIT(A) has erred on facts and in law by allowing the deduction u/s 10B of the IT Act, 1961 after adjustment of losses of other units owned by the assessee? 2. It is submitted that since the re-computation of deductio....

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....efore the learned CIT(A). 5. Learned CIT(A) found that the decisions referred by the assessee in the case of CIT Vs. M/s. Yokogawa India Ltd. (Civil Appeal No. 8498 of 2013)(Supreme Court) was also in favour of the assessee on merits. Moreover he found that the issue is in any case debatable and an order under section 154 of the Act cannot be passed on the subject. We may gainfully referred to ....

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....herefore, the rectification made by the AO in the order under 154 of the IT Act dated 23/03/2015 is beyond the scope of the provisions of section 154 of the IT Act. Accordingly, the order passed by the AO under section 154 of the IT Act is hereby quashed and set aside and the only ground of appeal raised by the appellant is allowed. 6. Against this order revenue is in appeal before us. 7. We....