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The High Court of Allahabad ruled in favor of the assessee-company regarding the development rebate claim. The Income-tax Officer should have allowed the assessee an opportunity to create a further reserve to meet the deficiency. The Tribunal held that rectification proceedings are part of the assessment proceedings, entitling the assessee to create a reserve until the proceedings are concluded. The questions of law were answered in favor of the assessee, who was awarded costs of Rs. 200. (Case citation: 1978 (4) TMI 67 - ALLAHABAD High Court)
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