2014 (6) TMI 574

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....age 4 and projected as a substantial question of law is concerned, the ITAT has noted that the very claim was subject matter in the Assessee's own case. In that the ITAT had directed the Assessing Officer to allow it. The details in that behalf are referred in paragraph 6 of the ITAT's order. The Chart would indicate as to how the same has been raised in the Assessment Years 1999-2000 till 2005-2006. The current year is 2006-2007. Mr.Suresh Kumar could not offer any explanation as to whether the Revenue has accepted this finding of the ITAT for the prior Assessment Years or whether the same has been questioned and challenged in appropriate proceedings. In the light of the fact that the Tribunal was dealing with the Company engaged i....

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....on of law. 5. Insofar as the question (c) in relation to Head Office Expenses is concerned, the findings of fact by the ITAT for the prior Assessment Years have been referred to and if at all any reference is needed, paragraphs 17 and 18 of the ITAT's order are complete answers. Therefore, the factual findings do not raise any substantial question of law in relation to this claim as well. 6 As far as question (d), namely, the claim relating to purchase price from Tata Power Company is concerned and that was for the deduction under Section 80IA, the ITAT in paragraph 21 onwards has noted the factual findings and also referred to the order of the Maharashtra Electricity Regulatory Authority (for short "MERC"). Paragraph 36 set outs as t....