Tata Consultancy Services Ltd. v. Dy. CIT [2023] 154 taxmann.com 372 / (2025) 129 ITR 667 (Mum.)(Trib.)

S. 254(1) : Appellate Tribunal-Powers-Additional ground-Pure question of law requiring no fresh investigation of facts-Admitted.[S.10AA, 139]

The assessee raised an additional ground before the Tribunal contending that deduction under section 10AA should be computed on commercial profits instead of income under the head “Profits and gains of business or profession”. The Tribunal held that the issue was purely legal and did not require investigation of fresh facts. The additional ground was admitted and the issue remanded to the Assessing Officer for fresh consideration. (AY. 2014-15).

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