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TMI Blog1999 (3) TMI 39X X X X Extracts X X X X X X X X Extracts X X X X ..... wo questions as refrained by him, which he submits are questions which require consideration by this court: "1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in deleting the additions of Rs. 19,726 and Rs. 1,01,301 made to the chargeable interest is per the order of the Commissioner of Income-tax under section 19 of the Interest-tax Act, 1974? 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case of the Revenue that any of those decisions have been taken up in appeal to the Supreme Court or that in any other matter the ratio laid down in the aforementioned decisions has been reversed by the Supreme Court. In the circumstances, we deem it unnecessary to call for a reference merely for the purpose of reiterating the law which has been declared and also accepted by the Revenue. A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... I to the ultimate borrower is in the circumstances an integrated transaction. The Tribunal has therefore in that background held that the interest received by the lending bank from the constituents for the monies lent by the bank from and out of the monies made available to it by the A. D. R. C. and the I. D. B. I. did not in its entirety accrue to the lending bank. It was in that sense the len ..... X X X X Extracts X X X X X X X X Extracts X X X X
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