2021 (8) TMI 74

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....al Member And Shri Waseem Ahmed, Accountant Member For the Appellant : Shri Virendra Ojha, CIT/D.R. For the Respondent : Shri Vartik Chokshi, A.R. ORDER PER BENCH The captioned appeals have been filed at the instance of the Revenue and the assessee has also filed CO against the order of the learned Commissioner of Income Tax (Appeals)- 12 Ahmedabad {(CIT-A in short)} dated 25 Septem....

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....pense under the head research and development which is 0.73% of the total expenses. Likewise, the assessee has also not furnished the supporting documents for packaging expenses incurred by it. 4. As per the AO, the assessee wa s showing higher amount of gross as well as net profit being a unit eligible for deduction under section 80IC of the Act which is nothing but the infla ted profit. As su....

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....n that whatever amount has been determined as income of the assessee, the same was allowed as deduction under section 80-IC of the Act, raising nil demand of tax. Accordingly the learned AR contended that the appeals filed by the Revenue should be dismissed in limine. 8. On the contrary, the learned DR agreed to the proposition projected by the learned AR for the assessee that the appeals filed....

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....gly, we hold that the appeals filed by the Revenue are not maintainable. 11. It is also pertinent to note that as there is no demand of tax in th e appeals filed by the Revenue, these appeals are also not maintainable in view of the CBDT Circular No. 17 of 2019 dated 8-8-2019. As per the circular all pending appeals filed by the Revenue are liable to dismissed as a measure for reducing tax liti....