9911796707
TMI Blog2019 (3) TMI 1168X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue to challenge the judgement of the Income Tax Appellate Tribunal. Following question is presented for our consideration:- "Whether, on the facts and in the circumstances of the case and in law, the Tribunal is justified in deleting the addition of Rs. 6,71,11,494/- on account of adjustment of the ratio for allocation of administrative and other expenses between tonnage and non-tonnage ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mon costs and attributable to the tonnage tax business shall be determined on a reasonable basis. (2) Where any asset, other than a qualifying ship, is not exclusively used for the tonnage tax business by the tonnage tax company, depreciation on such asset shall be allocated between its tonnage tax business and other business on a fair proportion to be determined by the Assessing Officer, having ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ratio of 67:33 by following "Annualised Operating Charter Hire Income Method". The A.O.rejected the system adopted by the assessee only in respect of administrative expenses. By applying direct income proportionate method, the A.O. allocated the administrative expenses to the extent of 73.06 % to the tonnage tax activity and rest 26.94 % to the non tonnage tax business. 5] The Tribunal in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eallocation of the administrative expenses rejecting the assessee's treatment which was based on "Annual Operating Charter Hire Income method", on the ground that in relation to other expenses namely, total operating expenses, interest and finance charges, the A.O. had accepted the method of accounting adopted by the assessee. Similarly, in relation to depreciation also, the A.O. had not make any ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
