Tribunal upholds CIT(A)'s decisions, dismisses Revenue's appeal on all grounds. Detailed analysis of legal provisions and case laws.

The tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on all three substantive grounds. The judgment provided detailed analysis of each issue, considering legal provisions, case laws, and factual circumstances to arrive at the final decision.

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Issues involved:
1. Disallowance under section 14A r.w.r. 8D
2. Disallowance under section 80IB
3. Disallowance of late payment of employees' PF contribution

Issue 1: Disallowance under section 14A r.w.r. 8D
The appellant's appeal for A.Y. 2011-12 challenged the CIT(A)-2, Kolkata's order reversing the Assessing Officer's disallowance of amounts under section 14A r.w. rule 8D. The tribunal upheld the CIT(A)'s decision as the assessee did not have any exempt income in the relevant assessment year. Citing a jurisdictional high court decision, the tribunal found no reason to interfere with the CIT(A)'s findings, leading to the Revenue's failure in this ground.

Issue 2: Disallowance under section 80IB
The dispute revolved around the disallowance of a deduction under section 80IB amounting to Rs. 3,83,86,013 related to a housing project. The Assessing Officer contended that the assessee had allotted more than one residential flat to multiple parties, violating the provisions of section 80IB(10). However, the CIT(A) reversed this action after considering the facts and legal provisions. Citing relevant case laws, the tribunal concluded that the statutory amendments had prospective effect and upheld the CIT(A)'s decision to allow the deduction entirely.

Issue 3: Disallowance of late payment of employees' PF contribution
The third issue concerned the disallowance of Rs. 70,355 for late payment of employees' PF contribution. The tribunal referred to a high court decision establishing that such payments made before the due date of filing return were allowable. Relying on this legal precedent, the tribunal rejected the Revenue's argument and dismissed the appeal, affirming the CIT(A)'s decision.

In conclusion, the tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on all three substantive grounds. The judgment provided detailed analysis of each issue, considering legal provisions, case laws, and factual circumstances to arrive at the final decision.

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