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Issues involved:
The judgment involves issues related to disallowance of interest u/s.14A, disallowance of administrative expenses u/s.14A, disallowance of provisions in diminution in value of investments u/s.28/37(1), charging of interest u/s 234B, and charging of interest u/s.234D. Disallowance of interest u/s.14A: The first issue in the appeal was regarding the disallowance of interest u/s.14A. The Commissioner of Income Tax (Appeals) confirmed the disallowance made by the Assessing Officer. The Tribunal referred to a previous decision in the assessee's own case and remitted the issue back to the Assessing Officer for reconsideration based on specific criteria related to interest paid on tax-free securities. The issue was allowed for statistical purposes. Disallowance of administrative expenses u/s.14A: The next issue was the disallowance of administrative expenses u/s.14A. The assessee decided not to press this issue due to the small amount involved, and it was dismissed accordingly. Disallowance of provisions in diminution in value of investments u/s.28/37(1): Another issue was the disallowance of provisions in diminution in value of investments as not allowable deduction u/s.28/37(1). The Tribunal held that this issue was covered by a previous decision and dismissed it accordingly. Charging of interest u/s 234B: The issue of charging interest u/s 234B was raised, and the Tribunal referred to previous decisions and upheld the charging of interest under Section 234B based on the finally assessed income. Charging of interest u/s.234D: The final issue was regarding the charging of interest u/s.234D. The Tribunal partially allowed this issue based on the applicability of Section 234D from a specific assessment year as per previous decisions. Separate Judgment (Revenue's Appeal): In the Revenue's appeal, the issue was related to the disallowance of depreciation on assets of sale and lease-back transactions. The Commissioner of Income Tax (Appeals) had deleted the disallowance, and the Tribunal referred to a previous decision in the assessee's own case to dismiss the issue, citing the principle of consistency in accepting depreciation claims from previous years. Overall, the assessee's appeal was partly allowed, and the Revenue's appeal was dismissed.
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