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TMI Blog2019 (4) TMI 2053X X X X Extracts X X X X X X X X Extracts X X X X ..... gpal, Sr. DR. For the Respondent : Shri Bandish Soparkar, A.R. ORDER PER SHRI KUL BHARAT, JUDICIAL MEMBER : These two cross appeals by the Assessee in ITA No. 1227/Ahd/2017 and ITA No. 1147/Ahd/2017. These two cross appeals by the Revenue and assessee are directed against the order of Commissioner of Income Tax(Appeals)-1, Vadodara ( CIT(A) for short) dated 01.02.2017 pertaining to the Assessment Year (AY) 2012-13. 2. First we take up the Revenue s appeal in ITA No. 1227/Ahd/2017. The Revenue has raised following grounds of appeal:- 1. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in allowing the interest of Rs. 6,09,54,788/- by treating it as business expenditure ignoring the fac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... following the same Ground No. 1 of the Revenue s appeal is rejected. 6. Ground No. 2 it is stated that this also covered by the decision of the Tribunal and ITA No. 2550/Ahd/2015 pertaining to the A.Y. 2011- 12. 7. Ld. DR did not controvert this fact that this issue is also covered by the decision of the Tribunal in earlier year therefore taking a consistent view the ground raised by the Revenue is dismissed. 8. Ground No. 3 is general in nature. There is need no separate adjudication. Appeal of the Revenue is dismissed. 9. Now coming to the assessee s appeal in ITA No. 1147/Ahd/2017. The assessee has raised following grounds of appeal:- 1. The order passed by the learned Commissioner of Income Tax (Appeals) [hereinafter r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3.3 Without prejudice to above, the learned CIT (A) grossly erred in not rectifying the errors in calculating amount of disallowance u/s 14A read with Rule 8D. 3.4 Without prejudice to above, the disallowance u/s. 14A read with Rule 8D ought to be substantially reduced. 4. Re: Levy of interest u/s. 234D: 4.1 On facts and circumstances of case, and in law, the learned CIT(A) grossly erred in not directing the Assessing Officer to correct the errors made in the computation of interest u/s. 234D. 5. The appellant craves leave to add to, alter, amend or delete any ground of appeal. 10. Ground No. 1 is general in nature and there is no need to separate adjudication. 11. Ground No. 2 Ld. Counsel for the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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