Tribunal rulings: AY 2010-11 dismissed, 2011-12 remanded for reassessment. Favorable ruling on section 80-IA claim.

The Tribunal dismissed the appeal and cross-objection for A.Y. 2010-11 due to the tax effect falling below the CBDT's monetary limit. For A.Y. 2011-12, the Tribunal allowed the assessee's appeal, remanding disallowances back to the AO for reevaluation. Regarding the claim under section 80-IA, the Tribunal ruled in favor of the assessee, emphasizing fair assessment and adherence to the law. The judgment stressed compliance with CBDT circulars and thorough consideration of all claims and grounds.

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Issues involved:
1. Appeal and cross-objection against orders passed by the Commissioner of Income Tax (Appeals) relevant to A.Y. 2010-11 & 2011-12.
2. Appeal against order dated 24.09.2014 by the revenue for A.Y. 2010-11.
3. Dismissal of appeal by revenue due to tax effect being less than the monetary limit set by CBDT circulars.
4. Appeal by assessee against order dated 18.05.2015 for A.Y. 2011-12.
5. Disallowance of interest, business penalty, and Provident Fund contribution by AO.
6. Dismissal of additional grounds by CIT(A) and subsequent appeal by the assessee.
7. Adjudication of claim under section 80-IA of the Income Tax Act.

Analysis:
1. The appeal and cross-objection were filed against orders passed by the Commissioner of Income Tax (Appeals) for A.Y. 2010-11 & 2011-12. The revenue's appeal for A.Y. 2010-11 was dismissed due to the tax effect being below the monetary limit set by CBDT circulars. The circulars enhanced the limit for filing appeals before the Tribunal to Rs. 50,00,000. The decision was based on the circulars and a Co-ordinate Bench ruling, allowing a miscellaneous application if the appeal falls within specified exceptions.

2. The assessee's appeal for A.Y. 2011-12 challenged various disallowances made by the AO, including interest payments, business penalty disallowance, and Provident Fund contribution. The CIT(A) dismissed additional grounds raised by the assessee, leading to the appeal before the Tribunal. The Tribunal found that the CIT(A) erred in dismissing the additional grounds and remanded the issues back to the AO for fresh examination and decision in accordance with law.

3. The claim under section 80-IA of the Income Tax Act was a crucial point of contention. The assessee's claim for deduction was not considered by the AO or CIT(A) adequately. The Tribunal directed the AO to re-examine the claim, emphasizing the need for a fair assessment and adherence to the law. The Tribunal decided in favor of the assessee against the revenue on this issue and set aside the CIT(A)'s findings.

In conclusion, the Tribunal dismissed the appeal and cross-objection related to A.Y. 2010-11, allowed the assessee's appeal for A.Y. 2011-12 for statistical purposes, and directed a fresh examination of the issues regarding disallowances and the claim under section 80-IA. The judgment highlighted the importance of adhering to CBDT circulars, fair assessment practices, and the need for thorough consideration of all claims and grounds raised by the parties involved.

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