Sami Labs Ltd Vs DCIT (ITAT Bangalore) – Assessee had to incur cultivation expenses to ensure adequate and steady supply of coleus plants from the farmers which were an essential input for the continuous processing in research and development activities of the assessee. Thus, these expenses incurred by the assessee for a commercial expediency and were wholly and exclusively for the purpose of its business. In essence, the authorities were not justified in disallowing the cultivation expenses of Rs.90.64 lakhs claimed by the assessee.
Sami Labs Ltd. Vs. The Dy. Commissioner of Income Tax
IN THE INCOME TAX APPELLATE TRIBUNAL
“B” BENCH : BANGALORE
ITA No. 417/Bang/2010
Assessment year : 2004- 05
O R D E R
Per A. Mohan Alankamony, Accountant Member
This appeal instituted by the assessee company is directed against the appellate order of the Ld. CIT (A)-III, Bangalore in ITA No:283/C-12(3)/ CIT(A)-III/BNG/06-07 dated: 30.12.2009 for the assessment year 2004-05.
2. The assessee company (‘the assessee’ in short) had raised ten grounds in an illustrative and exhaustive manner. Ground Nos: 1 and 10 being general in nature, they have become non-consequential. The issues raised in the remaining grounds are reformulated, for the sake of clarity, in a concise manner, as under:
