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of <h1>Tribunal partially grants appeals for multiple assessment years, remands issues for re-evaluation.</h1> <h3>Dharampal Premchand Ltd. Versus DCIT Central Circle – 29 New Delhi</h3> Dharampal Premchand Ltd. Versus DCIT Central Circle – 29 New Delhi - TMI Issues Involved:1. Speculation Loss in Future Trading2. Speculation Loss in Share Dealings3. Disallowance under Section 14A4. Disallowance of Loss on Revaluation of Shares5. Deduction under Section 10AASummary:1. Speculation Loss in Future Trading:The assessee did not press ground Nos. 1.1 and 1.2 related to the speculation loss in future trading and share dealings. These grounds were dismissed as not pressed.2. Disallowance under Section 14A:The AO disallowed Rs. 97,92,030/- under Section 14A, invoking Rule 8D, which the CIT(A) restricted to Rs. 28,14,818/-. The Tribunal restored the issue back to the AO to rework the disallowance under Section 14A r.w.r 8D, considering interest-free funds and investments yielding tax-free income, following the precedent set in A.Y. 2014-15.3. Disallowance of Loss on Revaluation of Shares:The AO disallowed Rs. 14,99,999/- claimed as a loss on revaluation of shares, which was upheld by the CIT(A). The Tribunal agreed with the lower authorities that the loss was not a business loss and dismissed this ground.4. Deduction under Section 10AA:The AO reduced the exemption claimed under Section 10AA by Rs. 52,06,176/- after allocating head office expenses and interest. The CIT(A) upheld the AO's decision. The Tribunal restored the issue back to the AO to re-compute the exemption under Section 10AA, considering the allocation of expenses and interest, following the precedent set in A.Y. 2014-15.Result:The appeals for A.Ys. 2013-14, 2015-16, 2016-17, and 2017-18 were partly allowed, with issues related to Section 14A and Section 10AA remanded back to the AO for re-evaluation.
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