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of <h1>ITAT Delhi: Appeal partially allowed on amortization, TDS credit. Rule 8D disallowance partially upheld.</h1> <h3>Krishak Bharti Cooperative Ltd. Versus ACIT, Circle-23 (1), New Delhi And Vice-Versa.</h3> Krishak Bharti Cooperative Ltd. Versus ACIT, Circle-23 (1), New Delhi And Vice-Versa. - TMI Issues Involved: Cross appeals filed by the assessee and revenue against the order of Ld CIT(A) for assessment year 2007-08.Assessee's Appeal (I.T.A. No.5292/Del/10):Grounds of Appeal:1. Disallowance of amount written off for amortization of lease amount paid towards land.2. Claiming refund u/s 244A(1)(b) and credit of TDS amount.3. Dispute over disallowance of lease amount based on previous assessment years' treatment.Decision:- Disallowance upheld based on previous ITAT Delhi Bench decisions.- Refund and TDS credit issues remitted back to Ld CIT(A) for proper adjudication.Revenue's Appeal (I.T.A. No.5446/Del/2008):Grounds of Appeal:1. Addition made under Rule 8D r.w.s. 14A of the IT Act.2. Disallowance of insurance premium paid.3. Disallowance of inventory loss claim.Decision:- Disallowance under Rule 8D partially allowed based on specific dividend income.- Insurance premium disallowance dismissed in favor of the assessee.- Inventory loss claim allowed as supported by documentary evidence and proper disclosure.Conclusion:Assessee's appeal partially allowed, and revenue's appeal allowed in part based on the above decisions made by the ITAT Delhi. The judgment was pronounced on 13th May, 2011.
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