2020 (8) TMI 106

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..... nit at Rudrapur in AY 2010-11 without rejecting the assessee's books of account. This tribunal's order in assessee's appeal [ 2019 (5) TMI 101 - ITAT KOLKATA] in the said earlier assessment year holds that such a record is not open to the department in absence of rejection of books of account. The very factual position continues in the impugned assessment year as well wherein the l .....

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..... Heard both the parties. Case file(s) perused. 2. The assessee's sole substantive grievance in the instant appeal seeks to reverse both the lower authorities' action restricting its Section 80IC deduction claim of ₹27,24,02,458/- to ₹27,16,80,866/- only thereby reallocating office expenditure of ₹7,21,592/- qua its three units; respectively. 3. The assessee/compa .....

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..... r unit share of expenses is 17.23% as against revenue generation of 7.23% only. 5. We find no merit in Revenue's foregoing stand. Case records indicate that both the lower authorities had made a similar estimation of allocation of expenses leading to disallowance of ₹3 lakhs qua the very eligible unit at Rudrapur in AY 2010-11 without rejecting the assessee's books of account. Thi .....

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