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TMI Blog2020 (3) TMI 230X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 80IA of the Act was ₹ 314.84/-. Lakhs. Therefore, the issue of revised claim made by the assessee of ₹ 690.35 Lakhs is of no consequence. Similarly, for the A.Y.1997-98, the assessee's total income prior to deduction under Section 80IA of the Act, 1961 stands assessed at ₹ 190.68 Lakhs. However, the eligibility to deduction under Section 80IA stands confirmed by the Assessing Officer at ₹ 354.02 Lakhs. Therefore, the consideration of revised claim of ₹ 487.39 Lakhs is no consequence as the assessed income is much less than the eligibility under Section 80IA of the Act, 1961. Disallowance of consultancy fees - HELD THAT:- Both, the CIT (A) and the Tribunal have given concurrent findings of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Tax Appeal No.1359 of 2008 is treated as the lead matter. 4.1 The respondent-assessee had filed its return of income on 13th November, 1995 for the A.Y.1995-96, declaring total income at ₹ 9,53,140/-. In the said return of income, the assessee had claimed deduction under Section 80IA of the Act, 1961 at ₹ 3,22,05,867/-. During the assessment proceedings, the assessee submitted a revised claim of deduction under Section 80IA of the Act, 1961 at ₹ 6,30,58,127/-. 4.2 The Assessing Officer, vide order dated 27th March, 1998 passed under Section 143(3) of the Act, 1961, rejected the revised claim of deduction made by the assessee under Section 80IA and limited it to the original claim of ₹ 3,22,05,867/- 4.3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l income of the assessee for the A.Y. 1995-96 even after inclusion of the disallowance made by the Assessing Officer was ₹ 314.84 Lakhs, against which the claim under Section 80IA allowed by the Assessing Officer was at ₹ 322.05 Lakhs. The Tribunal also considered that even the CIT (A) has also allowed the revised claim of deduction made by the assessee under Section 80IA of the Act, 1961 at ₹ 630.35 Lakhs keeping in mind the fact that the income of the assessee prior to deduction under Section 80IA of the Act was ₹ 314.84/-. Lakhs. Therefore, the issue of revised claim made by the assessee of ₹ 690.35 Lakhs is of no consequence. 6. Similarly, for the A.Y.1997-98, the assessee's total income prior to ded ..... X X X X Extracts X X X X X X X X Extracts X X X X
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