2021 (4) TMI 1205

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.... For Appellant: Mr.M.Swaminathan, Senior Standing Counsel For Respondent: Mr.R.Sivaraman JUDGMENT M. DURAISWAMY, J. Challenging the order passed in I.TA.No.1638/Mds/2013 in respect of the assessment year 2008-09 on the file of the Income Tax Appellate Tribunal, Chennai, "A" Bench, the Revenue has filed the above appeal. 2.The above appeal was admitted on the following substantial q....

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....of the materials available on record and the submissions made by Mr.M.Swaminathan, learned senior standing counsel appearing for the appellant - Revenue, it could be seen that the proceedings under Section 263 have been initiated by the Commissioner of Income Tax. The first reason cited in the show cause notice was that deduction under Section 10B has been allowed without excluding other incomes. ....

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.... specific directions with regard to specific expenditure or income claimed or suppressed by the assessee. Further, the Tribunal observed that the order passed by the Commissioner of Income Tax is a non-speaking and cryptic order. The Commissioner of Income Tax has not given any valid reason to come to the conclusion that the order passed by the Assessing Officer is erroneous and prejudicial to the....