S. 263 Non application of mind cannot be said Merely because AO has not dealt with an issue in Assessment Order

Issues Under Consideration (1) Whether, on the facts and in the circumstances of the case and in law, the Tribunal is justified in quashing the order under Section 263 of the Income Tax Act,1961 as undoubtedly, the expenditure of Rs.2.94 crores was incurred to create the brand “Nirvana” – an intangible asset ?  (2) Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in taking the view that the expenditure incurred by the assessee did not result in any kind of addition or augmentation of any profit making asset, when the assessee company itself ha...