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TMI Blog2019 (11) TMI 1633X X X X Extracts X X X X X X X X Extracts X X X X ..... as claimed for the first time in the return for the A.Y. 2009-10 which was not granted, but the ld. CIT(A) accepted the assessee s claim and the Revenue s appeal has been dismissed, albeit on low tax effect. No assessment was taken up u/s. 143(3) of the Act for the A.Y. 2010-11, meaning thereby that the deduction got allowed. From the above report of the AO, it is ostensible that the assessee h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee arises out of the order passed by the Commissioner of Income-tax (Appeals)-6, Pune on 03-07-2017 in relation to the assessment year 2011-12. 2. The only assail herein is to the confirmation of addition of ₹ 9.00 lakh made by the Assessing Officer (AO) u/s.35D of the Income-tax Act, 1961 (hereinafter also called `the Act ) by treating the amount as pre-operative expenses. 3. Suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is aggrieved by such confirmation of the addition. 4. I have heard both the sides and gone through the relevant material on record. In the course of an earlier hearing of this appeal, the ld. DR was required to submit a report on the granting or otherwise of deduction of such expenses of ₹ 9.00 lakh in the earlier years. A copy of the report from the AO has been placed on record ..... X X X X Extracts X X X X X X X X Extracts X X X X
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