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TMI Blog2018 (2) TMI 1789X X X X Extracts X X X X X X X X Extracts X X X X ..... s in granting the deduction u/s. 80IB of the Act of ₹ 28,54,26,054/- on interest income on FDI/ICD? C. Whether the Tribunal erred in law and on facts in deleting the addition made on account of upward adjustment u/s. 92CA(3) of the Act on account of guarantee fee on loans availed by AEs of Assessee against guarantee of Assessee?” - TAX APPEAL NO. 1000 of 2017 - - - Dated:- 20-2-2018 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by AEs of Assessee against guarantee of Assessee? 3. Revenue has proposed following three additional questions: 1. Whether the Tribunal erred in law and on facts in deleting the disallowance of ₹ 22,15,55,371/- being national loss on outstanding forex derivatives contracts as on 31.03.2009? 2. Whether the Tribunal erred in law and on facts in granting the deduction u/s. 80 I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in (2006) 284 ITR 401 Guj. So far as question No. 3 is concerned, the Tribunal referred to the judgement of Supreme Court in case of Goetz (India) Ltd. vs. CIT reported in (2006) 284 ITR 323 (SC) to entertain additional contention. Reference in this respect can be made by this Court in the decision in case of Commissioner of Income Tax vs. Mitesh Implex reported in (2006) 367 ITR 85 (Guj). 5. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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