2011 (3) TMI 1332

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..... issue and in that judgment the matter was remanded to AO to specifically consider the disallowance with reference to sub-clause (f) of Explanation to Section 115JA which was not considered by the assessing officer in that case. However, in this case, disallowance is specifically made with reference to the above provision, which is only Rs. 1 crore. Therefore following the judgment we allow the app .....

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..... ppeal No. 1883 of 2011 whereunder the Supreme Court has declared the requirement of approval by CoD for filing appeal as unnecessary. In this case question may arise as to whether the judgment of the Supreme Court applies only prospectively or not. However, in this case we do not think there is any need to consider the same because CoD approval is already obtained by the revenue for filing appeal. .....

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