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TMI Blog2013 (8) TMI 1019X X X X Extracts X X X X X X X X Extracts X X X X ..... , JM: These appeals filed by the assessee are directed against the orders of the Ld.CIT(A) 22, Mumbai all dated 29.09.2011 for the Assessment Years 2003-04, 2004-05, 2005-06 & 2006-07. All these appeals are disposed by way of this common order. 2. The only issue raised in the grounds of all these appeals relate to the addition of interest amounting to Rs. 6,68,233/-, 7,48,222/-, 8,38,234/- & 9, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r consideration on notional basis as the assessee had been following mercantile system of accounting and since the assessee had earlier offered income from interest on accrual basis for the assessment years 2001-02 and 2002-03. On appeal, the Ld.CIT(A) confirmed the action of the AO. Aggrieved by the impugned orders, the assessee has filed these appeals before us. 4. Before us, the Ld. AR has rei ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Hon'ble Supreme Court in the case of State Bank of Travancore Vs. CIT 158 ITR 102. On the other hand, the Ld. DR has relied on the orders of the AO and the Ld.CIT(A) in support of the Revenue's case. 5. We have heard both the parties and perused the material on record. It is not disputed that the assessee has been continuously following the mercantile system of accounting and the assessee ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed interest to the assessee as per their return cannot be the basis for giving relief to the assessee as the same has been assessed only on accrual basis and not on the basis of actual receipt. Also, the decisions relied by the Ld. AR are not applicable to the present case of the assessee as the facts are distinguishable in the line of the above discussed facts. In view of that matter, we do not f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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