2016 (12) TMI 545

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..... er B. R. Baskaran (AM) These cross appeals are directed against the order dated 30-11-2012 passed by Ld CIT(A)-27, Mumbai and they relate to the assessment year 2009- 10. 2. The tax effect involved in the appeal filed by the revenue is less than Rs. 10.00 lakhs and hence the same is required to be dismissed in view of the Circular No.21/2015 dated 10-12-2015 issued by CBDT. The Ld D.R did not di .....

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..... on expenses need to be allocated to SEZ unit. Accordingly he identified certain common expenses and apportioned the same in the ratio of turnover between head office and SEZ unit. Accordingly the AO allocated a sum of Rs. 24,09,095/- to SEZ unit out of expenses booked in the Head office. The AO also allocated a further sum of Rs. 5.00 lakhs to SEZ unit out of finance and other common expenses, whi .....

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..... ted that the SEZ unit was manufacturing diamond stud jewellery by purchasing readymade moulds and studding the diamonds therein. Hence the work carried on by the SEZ unit was not complicated one and hence the same did not require much of general & administrative expenses. He submitted that the books of accounts of earlier and subsequent years for SEZ unit have been accepted. Accordingly he contend .....

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..... onfirming the addition. 8. Having heard rival submissions, we are of the view that there is merit in the contentions of the Ld D.R. It is not in dispute that both Head office and SEZ unit are under common management. Further there is interlacing of funds also. The books of accounts of both the units were maintained by the assessee only. Hence it cannot be altogether ruled out that the benefit of .....

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..... remaining expenses confirmed by Ld CIT(A), in our view, the order of Ld CIT(A) does not call for any interference, since the allocation of those expenses in the sales ratio appears to be reasonable. Accordingly we confirm the order passed by Ld CIT(A) in respect of remaining expenses. 11. In the result, the appeal of the assessee is treated as partly allowed and appeal of the revenue is dismisse .....

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