9911796707
TMI Blog2011 (2) TMI 1553X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT, Circle-8, Ahmedabad u/s143(3) r.w.s 147of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') vide his order dated 29-12-2006. 2. The first issue in this appeal of Revenue is against the order of CIT(A) in directing the Assessing Officer to delete the disallowance out of garden expenses by treating such expenditure as rev expenditure u/s.37 of the Act. For this, Revenue has raised the following ground No.1:- "1. The ld. Commissioner of Income-tax(A)-XIV, Ahmedabad has erred in law and on facts in directing the Assessing Officer to delete the disallowance out of garden expenses ₹ 24,32,322/- by treating such expenditure as revenue expenditure u/s.37 of the Act." 3. At the outset Ld. Counsel for the assessee stated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is the duty of the assessee to make good the loss caused to nature and to prevent the health of thee workers engaged in production. Therefore, the assessee maintained the garden for maintaining better environment in the factory and the expenditure incurred in the process was therefore, for the purposes of the business of the assessee and was rightly allowed by the Learned Commissioner of Income Tax(Appeals). We therefore, confirm the order of the Learned Commissioner of Income Tax(Appeals) and dismiss the ground of appeal of the revenue." Respectfully following the same, we dismiss this issue in the appeal of Revenue. This issue of Revenue's appeal is dismissed. 4. The next issue in this appeal of Revenue is against the order of CIT(A) in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ket in overseas market and without registration of the products, the assessee-company would not be able to market the products in the overseas market. Further, these payments are made to drug regulatory authorities in various countries for the products market in the respective countries. Furthermore, these fees are to be paid on recurring basis depending upon the validity of the various registrations. The fees have been paid on expiry of the registration and out of total payment of ₹ 28,14,355/- major payment of ₹ 8,03,706/- is in respect of product registration in Poland. Likewise payments have been made in Vietnam, Russia, Ghana and China etc. We find that the exports over the years have increased from the export sale of ͅ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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