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TMI Blog2012 (11) TMI 987X X X X Extracts X X X X X X X X Extracts X X X X ..... on the question whether the assessee followed mercantile system of accounting or cash. In that view of the matter no question of law arises. Charge of interest u/s 234D - assessee submitted that when the Tribunal had remanded the main issue, at this stage, question of charging interest would not arise. - held that:- question would have no relation to system of accounting followed by Shiva Speci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that the assessee's system of accounting is 'cash' as against the view of the A.O. as 'Mercantile'? 2. Whether the Appellate Tribunal is right in law and on facts in restoring the issue of interest accrued of Rs.3,29,48,018/- on investment of Optionally Fully Convertible Premium Notes of Echolac Finvest Pvt. Ltd., Akshat Finstock Pvt. Ltd., Kautilya Fin Securities Ltd., Turkhiya Overseas P. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned counsel for the Revenue has drawn our attention to the relevant discussion of the Tribunal in this regard and contended that the Tribunal has heavily relied on its previous decision in the case of Shiva Specific Family Trust. He submitted that the said decision has been carried in appeal being Tax Appeal No.1368/08 and such Tax Appeal is admitted. Counsel for the assessee, however, submitted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essing Officer for fresh consideration on the question whether the assessee followed mercantile system of accounting or cash. In that view of the matter no question of law arises. We take note of the assertion of the counsel for the assessee that in so far as the present assessee is concerned, such question would have no relation to system of accounting followed by Shiva Specific Family Trust. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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