Allowability of sponsorship expenses in the absence of comment of AO in the original order
Court :
INCOME TAX APPELLATE TRIBUNAL
Brief :
On the facts and in the circumstances of the case, the ld.CIT(A) has erred in annulling the re-assessment proceedings u/s 147 on the basis of change of opinion by the AO on the issue of ‘allowability of Sponsorship Expenses’ even when the AO did not comment upon this issue either in the original order u/s 143(3) or in the Office Note appended thereto, the assessee’s claim of ‘Sponsorship Expenses’ having being a reasons for reopening of the original assessment.
Citation :
Deputy Commissioner of Income Tax,Central Circle-9,New Delhi.(Appellant) Vs. M/s SPA Enterprises Limited,303, D-2, Southern Park,District Centre Saket,New Delhi – 110 020.PAN: AACCS0628R.(Respondent)
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CS Bijoy
Published in Income Tax
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