2013 (11) TMI 71

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....d the judgement and order dtd. 2/11/2012 passed by the Income Tax Appellate Tribunal in ITA No.2399/Ahd/2008 for AY 2005-06 raising the following substantial questions of law for our consideration :- (A) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in upholding the decision of the CIT(A) and thereby deleting the disallowance u/s. 80IB(10) without ap....

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....g fiction created by the penal section 40(a)(ia) of the Act and therefore, the effect of the same cannot be imported into a beneficial provision vis-a-vis section 80IB(10) of the Act? 2.00. So far as question No.(A) is concerned, it is submitted by Mr.Parikh, learned counsel appearing on behalf of the appellant - revenue that the same is squarely covered against the revenue by virtue of the decis....