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TMI Blog2014 (9) TMI 47X X X X Extracts X X X X X X X X Extracts X X X X ..... HIGH COURT DELHI] - the defence taken by the assessee that the FDRs on which interest had accrued or was paid, had been obtained for issue of bank guarantee or for taking overdraft facility for the purpose of business – the defence was bonafide and the assessee has been able to discharge onus under Explanation to Section 271(1)(c) – thus, the order of the Tribunal is upheld – Decided against Reven ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble for deduction under Section 10A of the Act and addition of ₹ 44,36,745/- was made. This addition was sustained in the first appeal and then by the tribunal vide order dated 30th April, 2010. 2. Before the tribunal various contentions were raised on behalf of the respondent assessee including the fact that the FDRs had been furnished and given as security for obtaining overdraft limits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 271(1)(c). It is noticed that the said defence was consistently taken by the assessee from the beginning. This was the legal submission even in the assessment proceedings and then in the penalty proceedings. The question had not been adjudicated and decided in earlier years in the case of the assessee. 4. Looking at the order passed and the defence taken by the respondent assessee, it c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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