2015 (6) TMI 143

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..... e obtaining of a packing credit loan or payment of interest thereon in India cannot be said to entail the performance of any service outside India. This expenditure is, therefore, not deductible. See KEC International Ltd. vs. Commissioner of Income Tax, Central Range-II (2009 (1) TMI 5 - BOMBAY HIGH COURT)- Decided against assesse. - Income Tax Reference No. 459 of 1998 - - - Dated:- 7-5-2015 - .....

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..... -respondent before this Court is a private limited company. The assessment year involved is 1977-78 for which the accounting year ended on 31st January, 1976. The Income-tax Officer while computing the total income of the assessee allowed deduction under section 35B of ₹ 5,68,756/-. This amount was 1/3rd of the expenses of ₹ 17,06,269/- which the Income-tax Officer considered as eligib .....

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..... ion Bench judgment of this Court in the case of KEC International Ltd. vs. Commissioner of Income Tax, Central Range-II (2010) 322 ITR 465. The Division Bench held that weighted deduction is permissible and to the extent indicated in the judgment of the Andhra Pradesh High Court in the case of Commissioner of Income-tax vs. Coromandel Agro Products Oil Limited (1998) 230 ITR 335. The Division Benc .....

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