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TMI Blog2015 (10) TMI 1604X X X X Extracts X X X X X X X X Extracts X X X X ..... this appeal of assessee is against the order of CIT(A) confirming the action of AO in disallowing the expenses of Research & Development. For this, assessee has raised following three grounds: "1. For that under the facts and circumstances of the case the Ld. Assessing Authority and the Ld. Appellate Authority failed and neglected to appreciate the facts and nature of business carried on by the petitioner company and the entire observations in respect to such disallowance of expenses which arises out of Research & Development work of oneequipment for control of vehicle pollution, is bad in law and liable to be quashed. 2. For that the Ld. Appellate Authority as well as the Ld Assessing Authority should have appreciated that the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bmission put forward by the appellant along with the supporting documents furnished, perused the facts of the case including the finding of the AO in the impugned assessment order and the other materials brought on record. I have also gone through the contents of the various correspondences made by the appellant with the Transport Department, Govt. of West Bengal and with ARAI and the nature of Proforma Invoice for advance payment made. I do not find any substantial force in the argument put forward by the appellant. On the other hand I do find convincing reasoning in the observation of the AO that the project expenses written off were incurred by the appellant in past years in connection with the testing of Multi Fuel System by Automotive ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the expenses are not expended wholly and exclusively for the purpose of business as no business activity in past years or in the relevant year are carried out, which can be said to be related to Multi Fuel System. He further opined that these expenses relates to prior period i.e. incurred in FY 2004-05 relevant to AY 2005-06 and not to the FY 2005-06 relevant to AY under dispute 2006-07. Today, when Ld. counsel for the assessee was enquired about the year of incurring of these expenses and also whether the assessee is in the business of pollution control devices, he categorically admitted that this is a new line of business, which was to be started. According to him, this was on- going process and these expenses are for earning of future i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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