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TMI Blog2016 (3) TMI 1316X X X X Extracts X X X X X X X X Extracts X X X X ..... misplaced as that Circular refers to the decision of the Tribunal Special Bench, Vishakhapatnam in the case of Merilyn Shipping & Transports vs. Addl. CIT [2012 (4) TMI 290 - ITAT VISAKHAPATNAM]. The Circular also refers to the decision of the Hon’ble High Court of Gujarat, High Court of Allahabad which all relates to the issue relating to “paid or payable” whereas the issue before us relates to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : 1. These two appeals by two different assessees are directed against two separate orders of the ld. CIT(A)-II, Surat dated 06.10.2015. 2. As both these appeals involve common issues, these were heard together and are disposed of by this common order for the sake of convenience. 3. The common grievance in both these appeals relates to the holding that the amendment to Section 40(a)(ia) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ught in the explanation. However, this claim of the assessee did not find favour with the A.O, who was of the firm belief that the amendment is applicable from A.Y. 2013-14 onwards and accordingly made the disallowance of interest. 6. Assessee carried the matter before the ld. CIT(A) but without any success. Before us, the ld. counsel for the assessee stated that the issue is no more res integr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lso refers to the decision of the Hon ble High Court of Gujarat, High Court of Allahabad which all relates to the issue relating to paid or payable whereas the issue before us relates to the amendment of second proviso to Section 40(a)(ia) which has been held to have a retrospective effect by the Hon ble High Court of Delhi in the case of Ansal Landmark Township Pvt. Ltd. 279 CTR 384. 8. Howe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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