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TMI Blog2018 (8) TMI 1965X X X X Extracts X X X X X X X X Extracts X X X X ..... ss - HELD THAT:- Ancillary objects in the Memorandum of Association also permitted the assessee company to carry on the business of financial services. In the process the assessee company had deployed its fund towards earning interest income because during the relevant assessment year the assesse company did not commenced activities with respect to Hotel Business. Since the business of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nkamony, This appeal by the assessee is directed against the order passed by the learned Commissioner of Income Tax(Appeals)-15, Chennai, dated 10.02.2017 in ITA No.57/A.Y.2012-13/CIT(A)- 15/2015-16 for the assessment year 2012-13 passed U/s. 250(6) r.w.s. 143(3) of the Act. 2. The assessee has raised several grounds in its appeal however the crux of the issue is that the Ld.CIT(A) has erre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of ₹ 2,06,42,360/- because the assessee had only earned interest income and the company had not started the operation with respect to hotel and resort business. On appeal the Ld.CIT(A) allowed interest and miscellaneous expenditure to the tune of ₹ 56,42,360/- against the interest income earned by the assessee, however disallowed the expenditure of ₹ 1,50,00,000/- being the exp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther source. Hence it was pleaded that the order of the Ld.CIT(A) may be confirmed. 6. We have heard the rival submissions and carefully perused the materials on record. From the facts of the case, it is abundantly clear that during the relevant assessment year, the assessee was only engaged in the business of financial services though the main objects in the Memorandum of Association was Hotel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndulging in any other business activity during the relevant assessment year. Therefore we are of the considered view that the expenditure incurred by the assessee towards salary for ₹ 1,50,00,000/- has also to be allowed as deduction while computing the business income of the assessee for the relevant assessment year. Accordingly we hereby direct the Ld.AO to delete the addition of ₹ 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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