2013 (7) TMI 365

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..... njiv Khanna, J. (Oral) This appeal under Section 260A of the Income Tax Act, 1961 (Act, for short) by the Revenue, which relates to the assessment year 1998-99 raises two issues. The first issue pertains to deletion of disallowance on account of brand-building and dealer‟s loyalty expenditure. The said issue is covered against the Revenue by decision dated 3rd September, 2012 in ITA 98/2010 .....

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..... of the employees, mainly engineers and technicians, were sent to various plants in Indonesia, Bangkok and Seoul but the said training was given before commencement of the business of manufacturing which started from 17th June, 1997. The technicians were trained abroad during the period February-March 1997. 3. The contention of the assessee, which has been accepted by the tribunal, is though manu .....

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..... tup and whether the manufacturing activity was in continuation of the earlier business. The first appellate authority has, however, recorded that the respondent-assessee had commenced its business during the previous year in 1995-96 and training was given in March, 1997. 4. Pertinent observations have been made in Commissioner of Income Tax v. Cement and Chemical Industries Ltd. [1973] 91 ITR 170 .....

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