COMMISSIONER OF INCOME TAX Vs. ORIENT LONGMAN LIMITED

JUDGEMENT

(1.) THE revenue filed this appeal feeling aggrieved by the order dated 22.02.2001 of Hyderabad Bench B of Income Tax Appellate Tribunal.

(2.) THE assessee filed the income tax returns for the assessment year 1993 -94. He claimed the benefits under Section 80HHC and 80 Q of the Income Tax Act (for short, the Act). The Income Tax Officer disallowed as many as 12 such claims, aggregating to Rs.26,61,320/ -. The respondent filed appeal before the Income Tax Commissioner. The appeal was partly allowed through order dated 27.06.1996. While the respondent filed I.T.A.No.1614/Hyd/1996 feeling aggrieved by the denial of part of the relief by the Commissioner, the Department filed I.T.A.No.1626/Hyd/1996 challenging the correctness of the relief granted by the Tribunal. Through the order under appeal, Tribunal allowed I.T.A.No.1614/Hyd/1996 and dismissed the I.T.A.No.1626/Hyd/1996.

(3.) SRI C.V. Narasimham, learned counsel for the assessee, on the other hand, submits that extensive discussion on each and every item was undertaken not only by the Income Tax Commissioner but also appellate authority and the Tribunal did not feel it necessary to repeat the same. He submits that for all practical purposes, the Tribunal has agreed with the conclusion arrived at by the appellate Commissioner and though it would have been better to mention some more reasons, the failure to deal with the points in detail, cannot be said to be fatal.