2012 (10) TMI 1219 - HC - Income Tax

Summary

Issues involved: Revenue's appeal on multiple questions of law.

Question (a):
The Revenue raised five questions of law, but counsel for the Revenue conceded that question (a) does not arise from the Income Tax Appellate Tribunal's order and thus cannot be entertained.

Question (c):
Regarding question (c), the Revenue accepted the Income Tax Appellate Tribunal's decision in the assessee's case for a previous assessment year, stating no grounds exist for a different view. Therefore, question (c) was not entertained in this appeal.

Question (d):
Similarly, in relation to question (d), the Tribunal had previously allowed the assessee's claim based on its decisions for earlier assessment years, which had not been challenged by the Revenue. No justification was found to dispute the Tribunal's decision for the current year or the prior years, leading to the decision not to entertain question (d).

Admitted Questions:
The appeal was admitted on questions (b) and (e) which pertained to the justification for deleting disallowances made by the Assessing Officer for temple expenses and community welfare expenses claimed by the assessee company. The Tribunal's decisions on these matters were considered for further review in the appeal.