Tribunal Grants Appeals for 2013-2014 and 2015-2016 Assessments, Dismisses 2014-2015 Appeal

The Tribunal allowed the appeals for assessment years 2013-2014 and 2015-2016 for statistical purposes, directing a reconsideration of the disallowance under section 80IA. However, the appeal for assessment year 2014-2015 was dismissed regarding the addition of interest under section 244A and the disallowance of interest paid under section 201(1A) of the Income Tax Act.

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Issues:
- Disallowance u/s 80IA (Asst.Years 2013-2014 & 2015-2016)
- Interest u/s 244A (Asst.Year 2014-2015)
- Interest of Rs. 24,644 paid u/s 201(1A) of the I.T.Act (Asst.Year 2014-2015)

Disallowance u/s 80IA (Asst.Years 2013-2014 & 2015-2016):
The Assessing Officer disallowed the claim u/s 80IA for Rs. 3,11,713 and Rs. 37,82,522 for assessment years 2013-2014 and 2015-2016, respectively, due to expenses like managerial remuneration, audit fee, etc. The CIT(A) upheld the disallowance, stating the appellant failed to provide evidence of separate accounting for 80IA units. The Tribunal noted that for AY 2012-2013, the matter was remanded back to the CIT(A), directing a fresh decision. Considering identical facts, the Tribunal directed the CIT(A) to reconsider the issue, allowing the grounds for AYs 2013-2014 and 2015-2016 for statistical purposes.

Interest u/s 244A (Asst.Year 2014-2015):
The Assessing Officer added interest received on refund u/s 244A to the total income for AY 2014-2015. The CIT(A) confirmed this addition. The Tribunal upheld the decision, stating that since the interest was received during the relevant assessment year, it should be taxed as income from other sources, rejecting the appeal against the addition of Rs. 1,53,504.

Interest of Rs. 24,644 paid u/s 201(1A) of the I.T.Act (Asst.Year 2014-2015):
The Assessing Officer disallowed the deduction of Rs. 24,644 paid u/s 201(1A) as interest expenditure, citing statutory obligations for tax deduction. The CIT(A) upheld this decision. The Tribunal concurred, referencing the Supreme Court's ruling that interest for late payment of direct taxes is not deductible. Consequently, the appeal against disallowance was rejected.

In conclusion, the appeals for AYs 2013-2014 and 2015-2016 were allowed for statistical purposes, while the appeal for AY 2014-2015 was dismissed.

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