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Issues involved:
1. Disallowance of broken period interest on purchase of securities 2. Disallowance of non-rural bad debts written off out of contingency accounts 3. Disallowance of public issue expenses claimed under section 35D 4. Disallowance of proportionate expenses in respect of dividend income Issue 1: Disallowance of broken period interest on purchase of securities: The appeal was filed against the CIT(A)'s order regarding various additions/disallowances. The issue of interest on purchase of securities for the broken period was discussed, and it was agreed that a Bombay High Court decision favored the assessee. Consequently, the disallowance was reversed, and the finding of the CIT(A) was deleted. Issue 2: Disallowance of non-rural bad debts written off out of contingency accounts: The second issue involved the disallowance of bad debts written off out of contingency accounts. The appellant cited specific cases supporting their claim, and the DR conceded that the issue favored the assessee. However, the quantification of the deduction was referred back to the Assessing Officer for compliance with relevant tax provisions. Issue 3: Disallowance of public issue expenses claimed under section 35D: Regarding the disallowance of the deduction under section 35D for public issue expenses, the Assessing Officer denied the claim as the appellant was not considered an industrial undertaking. The CIT(A) upheld this decision, emphasizing the requirement for manufacturing or production in industrial undertakings. The appellant argued that as a service industry, they qualified as an industrial undertaking. However, the tribunal agreed with the Revenue authorities that the deduction under section 35D was not applicable to the financial services provided by the appellant. Issue 4: Disallowance of proportionate expenses in respect of dividend income: The final issue concerned the deduction allowed under section 80M after deducting proportionate expenses from the gross dividend received. The appellant contended that no expenses were attributable to the dividend income. The tribunal noted that the CIT(A) confirmed the disallowance without considering the actual expenditure incurred in earning the dividend income. Consequently, the issue was remanded to the Assessing Officer for determining the actual expenditure related to earning dividend income and recomputing the deduction under section 80M accordingly. In conclusion, the appeal was partly allowed, addressing various disallowances and deductions based on the specific legal interpretations and case laws cited by the parties involved.
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