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(PER SWATANTER KUMAR, C.J.) Assessee M/s Parle Products Ltd. filed return for the assessment year 1990-91 declaring a total income of Rs.11,28,05,040/-

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after claiming various deductions. Assessing Officer vide his order dated 19th March 1993 amongst others recomputed the deductions under Section 32-AB of the Income Tax Act, 1961 (hereinafter referred to as "the Act") and reduced the excess claim and granted reduction under the said provisions of Rs.1,66,86,614/- and assessed total income on Rs.12,46,75,532/-. The Assessee challenged this order before the Commissioner of Income Tax (Appeals), Bombay, and questioned the correctness and legality of the said order with particular emphasis on incorrect computation of deduction under Section 32-AB of the Act. The Commissioner of Income Tax (Appeals) affirmed the findings recorded by the Assessing Officer and held as follows :-