1(4) 205206, J.K. Chambers, Mumbai Sector17, Vashi, Navi Mumbai 400 705 PAN/GIR No.AACCN8633K (Appellant) .. (Respondent) Assessee by Shri Vijay Mehta, CA & Shri Tarang Mehta Revenue by Shri Satyaprakash R. Singh, CIT DR Date of Hearing 07/08/2025 Date of Pronouncement 12/08/2025 आदे श / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the Revenue against order dated 24/12/2024 passed by ld. CIT(A)46, Mumbai for the quantum of assessment passed u/s.143(3) for A.Y. 201819. 2. In the grounds of appeal, the Revenue has raised following grounds: 2 ITA No.1846/Mum/2025 Navkar Corporation Limited 1. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in fully allowing the deduction under Section 801A(4)(i) without verifying whether the assessee had maintained separate books of accounts, as mandated by Section 801A(5), and whether the accounts were retrospectively prepared only during assessment proceedings?" 2. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in granting full deduction under Section 801A without appreciating that the assessee failed to distinguish between receipts attributable to eligible and ineligible businesses, thereby inflating profits eligible for deduction?" 3. "Whether, on the facts and circumstances of the case and in law, the CIT(A) was justified in accepting the assessee's apportionment of common expenses (such as finance charges, employee costs, and other overheads) on a turnover basis, despite the AO finding the method arbitrary and inconsistent with actual business operations?" 4. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in rejecting the AQ's computation of eligible profits, which was based on an objective 65.88:34. 11 allocation ratio (used by the assessee itself for expenses), and instead adopting an inflated computation without sufficient justification? 5. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in ignoring the AO's finding that the assessee had not provided any evidence of how loans and financial liabilities were allocated between eligible and ineligible units, thereby affecting the accuracy of expense allocation and profit computation?" 6. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in disregarding the AO's reliance on Section 801A(8) proviso, which allows the AO to compute profits on a reason reasonable basis in cases where true profits cannot be determined due to lack of proper accounts? 7. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in allowing the claim of loss on sale of 3 ITA No.1846/Mum/2025 Navkar Corporation Limited fixed assets without verifying the depreciation details and Written Down Value (WDV) of assets as computed by the AO?" 8. "Whether, on the facts and circumstances of the case and in law, the CITTA) erred in allowing the claim without calling for a remand report, thereby failing to give the AO an opportunity to verify new evidence submitted during appellate proceedings?" 9. "Whether, on the facts and circumstances of the case and in law, the CIT(A) erred in disregarding the AO's findings that the block of assets resulted in a net profit of 233,34,380/instead of a loss, and therefore, no loss deduction was allowable under Section 32 of the Income Tax Act, 1961?" 3. The brief facts qua the issue involved are that the assessee company is mainly engaged in providing composite infrastructure facility by providing Container Freight Stations (CFS) within the notified Custom Zone, extended Inland Port facility for import and export of goods. The assessee owns and operates three CFS located in state of Maharashtra and one CFS located in state of Gujrat. The return of income was e filed on 28092018 for the year under reference declaring total income of Rs.35,20,50,000/ The said income wa