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TMI Blog2013 (7) TMI 365X X X X Extracts X X X X X X X X Extracts X X X X ..... st Revenue. - ITA 132/2010 - - - Dated:- 9-7-2013 - Sanjiv Khanna And Sanjeev Sachdeva,JJ. For the Appellant : Ms. Suruchi Aggarwal, sr. standing counsel For the Respondent : Mr. Satyen Sethi and Mr. Arta Tarana Panda, Advocates JUDGMENT Sanjiv Khanna, J. (Oral) This appeal under Section 260A of the Income Tax Act, 1961 (Act, for short) by the Revenue, which relates to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he year 1998-99. Assessee filed first appeal but the CIT (Appeals), instead of agreeing with the assessee, disallowed the entire expenditure holding that it relates to pre setup period‟ and was capital expenditure. The CIT (Appeals) observed that some of the employees, mainly engineers and technicians, were sent to various plants in Indonesia, Bangkok and Seoul but the said training was giv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it over a period of six years. The first appellate authority took notice of the fact that actual manufacturing activity commenced from 17th June, 1997, but did not go into the question as to the date on which business activities commenced i.e. business was setup and whether the manufacturing activity was in continuation of the earlier business. The first appellate authority has, however, recorded ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the course of carrying on the business as the subsequent activities of manufacture of cement and sale of manufactured cement. This activity came first in point and laid foundation for others and, hence, was held to be deductible in computing the trading profits of the assessee for the relevant assessment years. 5. In view of the findings recorded by the tribunal, we do not think that any sub ..... X X X X Extracts X X X X X X X X Extracts X X X X
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