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TMI Blog2015 (9) TMI 1060X X X X Extracts X X X X X X X X Extracts X X X X ..... distribution expenses and administrative expenses. These details have been set out in the order of the CIT (A). The ITAT has also concurred with the finding of the CIT (A). As regards the plea concerning Rule 46 A of the IT Rules, the Court finds that no such point was urged by the Revenue before the ITAT. The Court does not propose to permit the Revenue to urge such question for the first time in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... three points have been urged before us by Mr. Rahul Chaudhary, learned Senior standing counsel for the Revenue. 3. The first pertains to a sum of ₹ 31,39,625 which was disallowed by the Assessing Officer ('AO') on the ground that it was incurred as sales and distribution expenses by the Assessee on behalf of the sister concerns. The second pertains to ₹ 22,43,445 which was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing was granted by the CIT (A) to the AO in regard to such additional evidence. 5. It is seen that before the CIT (A), the Assessee did produce the details on the basis of which the CIT (A) reduced the disallowance proportionate to the expenditure incurred on behalf of the sister concerns both as regards the sales and distribution expenses and administrative expenses. These details have been se ..... X X X X Extracts X X X X X X X X Extracts X X X X
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