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2014 (10) TMI 741

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....e assessee is in appeal against the order passed by the Income Tax Appellate Tribunal, Ahmedabad Bench (hereinafter referred to as ITAT) dated 20.07.2001 in ITA No. 2708/Ahd/95 for the Assessment Year 1991-92 raising following questions for our consideration: (1)Whether, in the facts and circumstances of the case the ITAT was right in law in holding that the interest income amounting to Rs. 1,90,....

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....nsideration, the assessee claimed deduction u/s 80HH and 80-I. The appellant was denied deduction under sections 80HH and 80I of the Act on the interest amounting to Rs. 190034/- on the deposit with IDBI as required u/s 32AB of the Act as well as interest amounting to Rs. 109490/- on deposits placed with banks for getting bank guarantees in favour of the Forest Departments for the purchases of Ten....

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.... amount of interest on borrowings for business, such interest expenditure should be set off against the impugned interest income and only the net amount so arrived at may be excluded for the purpose of computing deduction u/s 80HH and 80I of the Act. The ITAT rejected this alternate plea of the appellant as well. 2.2 Being aggrieved and dissatisfied with the impugned judgment and order passed by ....

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....cision of this Court in the case of Commissioner of Income Tax, Ahmedabad vs. Nirma Ltd. passed in Tax Appeal No. 811 of 2013 on 27.01.2014. Mr. K.M. Parikh, learned advocate appearing for the respondent - revenue has relied on the decision of the Apex Court in the case of Liberty India vs. Commissioner of Income Tax reported in (2009) 317 ITR 218 (SC) so far as question no. 1 is concerned. 5. Ha....