Dipak Kumar Sen, J. - (1.)Gordhandas Jerambhai, the assessee, a registered firm, was assessed to income-tax for the assessment year 1971-72, the corresponding previous year ending on October 31, 1970. In the assessment proceeding, the assessee claimed weighted deduction for export markets development allowance under Section 35B of the I.T. Act, 1961. The ITO rejected the claim on the ground that full details and evidence had not been furnished.
(2.)The assessee preferred an appeal against the assessment to the AAC, inter alia, against the disallowance of its claim under Section 35B. Evidence was produced before the AAC to establish that the assessee was exporting jute and tea to foreign countries and in connection therewith had incurred travelling expenses amounting to Rs. 6,337. The AAC accepted the evidence and directed the ITO to allow deduction to the assessee under Section 35B to extent as claimed.
(3.)Against the order of the AAC, the assessee preferred a further appeal to the Income-tax Appellate Tribunal and, in the appeal, filed a petition to raise additional grounds of appeal claiming further weighted deduction under Section 35B of the said Act in respect of its other expenditure incurred in connection with its export business amounting to Rs. 4,37,502 and in connection with export promotion amounting to Rs. 2,29,454.