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TMI Blog2025 (3) TMI 596X X X X Extracts X X X X X X X X Extracts X X X X ..... Ananthan, C.A. And Ms. Lalitha Rameswaran, CA ORDER PER GEORGE GEORGE K, VICE PRESIDENT: This appeal at the instance of the Department is directed against CIT(A) - NFAC order dated 14.10.2024, passed under section 250 of the Income Tax Act, 1961 (hereinafter called 'the Act'). The relevant Assessment Year is 2010-11 2. The grounds raised are read as under:- "1. The order of Ld.CIT(A) is oppo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der dated 23.03.2016. In the said reassessment order, AO had disallowed interest payment of Rs. 1,35,56,446/- u/s. 40(a)(ia) of the Act for not deducting tax at source. 4. Aggrieved by the order of AO, assessee preferred appeal before First Appellate Authority. The CIT(A) following the ITAT order in assessee's own case [in Department appeal in ITA Nos.1315 & 1316/Chny/2018 dated 09.07.2019 for AY ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 194A of the Act and amendment made by Finance Act, 2015. The decision of the Id. CIT(A) is based on proper appreciation of the legal position. Accordingly, we do not find any merits in the ground No.7 raised by the Revenue. Ground No.7 of the Revenue is dismissed." 8. In the instant case, since assessment year concerned is 2010-11 and amendment to section 194A of the Act, is applicable f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ements of the Hon'ble Bombay High Court in the cases of Gandhibag Sahakari Bank Ltd. Vs. DCIT (2023) 9 TMI 1344 (Bom) and Sociedade De Fomento Industrial Pvt. Ltd. & Shantilal Khushal Das & Bros P.Ltd Vs. ACIT (2024) 1 TMI 1080 (Bom) in support of his submissions that reopening of assessment is bad in law. However, since we have decided the issue on merits in favour of the assessee, legal contenti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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