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TMI Blog2013 (2) TMI 712X X X X Extracts X X X X X X X X Extracts X X X X ..... were its own funds and also that section 10 of the Act provides for a deduction of net income and not gross income? - Held that:- Tribunal in the impugned order upheld the finding of the CIT(A) wherein a finding of fact has been reached that the dividend earned on shares by the respondent assessee is from its investments in shares out of the respondent-assessee's own funds. Consequently, the quest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appeal admitted on question (a) - Whether the ITAT is correct in deleting the addition made by the A.O. on account of interest paid by Indian Branch of the assessee bank to its head office and other overseas branch without considering the fact that the payments made by the branch to the Head office is considered interest and such interest is taxable under Article 13? - - IT Appeal (L) No. 1776 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expenditure incurred in earning exempt income without appreciating the fact that assessee did not demonstrate before the A.O. that the funds used for acquiring shares of LVL were its own funds and also that section 10 of the Act provides for a deduction of net income and not gross income? (c) Whether the Tribunal is correct in upholding the decision of CIT(A) in directing the A.O. to accept th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reason to entertain question (b). 4. So far as question (c) is concerned, the issue is whether the commission received by the respondent from its client to provide Guarantee is to be taxed in the year of the agreement (the year of the receipt) to provide the guarantee or to be spread over the period for which the guarantee is provided. In the present facts, CIT(A) has come to a finding of fact ..... X X X X Extracts X X X X X X X X Extracts X X X X
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