Appeals allowed on depreciation, carry forward losses pending decision. Interest on refunds dismissed.

The appeals related to the disallowance of amortization of depreciation on investments were allowed for statistical purposes, pending the High Court's decision. The issue of carry forward losses from earlier years was allowed for further consideration by the Assessing Officer. Appeals seeking interest on interest due to refund delays were dismissed based on statutory provisions and judicial precedent.

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Issues:
1. Disallowance of amortization of depreciation on investments.
2. Carry forward of losses from earlier years.
3. Granting interest on interest due to delay in refund.

Analysis:

Issue 1: Disallowance of Amortization of Depreciation on Investments
- The assessee, a resident corporate engaged in cooperative banking, claimed amortization of depreciation on investments held in different categories.
- Investments were shifted to Held to Maturity category with a reduction in value, leading to amortization charges.
- The AO disallowed the claim, upheld by CIT(A) following tribunal's order, leading to the appeal.
- The AR highlighted similar disallowances in previous years pending before the High Court.
- The matter was restored to the AO under Section 158A pending the High Court's decision, allowing the appeal for statistical purposes.

Issue 2: Carry Forward of Losses from Earlier Years
- The AO adjusted carried forward losses of certain years against current income, but the assessee claimed losses from years before AY 2007-08 were to be adjusted first.
- CIT(A) suggested addressing the issue under Section 154, leading to the appeal.
- The matter was restored to the AO with directions to substantiate the claim, allowing the appeal for statistical purposes.

Issue 3: Granting Interest on Interest Due to Delay in Refund
- In AY 1986-87 and 1997-98, the assessee sought interest on interest due to the delay in refund, citing judicial precedents.
- However, the Tribunal found no provision in the Income Tax Act for such interest and was bound by statutory provisions.
- Following the judgment in CIT vs Gujarat Fluoro Chemicals, the appeals were dismissed, denying compensatory interest on interest due to delay in refund.

Conclusion:
- Appeals related to amortization of depreciation were allowed for statistical purposes, pending the High Court's decision.
- The issue of carry forward losses was allowed for further consideration by the AO.
- Appeals seeking interest on interest due to refund delays were dismissed based on statutory provisions and judicial precedent.

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