2014 (11) TMI 592

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....way of this appeal, the Revenue has challenged the impugned judgment and order dated 6.1.2000 passed by the Income Tax Appellate Tribunal, Ahmedabad Bench 'C', Ahmedabad in ITA No.3331/Ahd/1994 for the Assessment Year 1990-91. 2. This appeal was admitted to consider the following substantial questions of law:        A) "Whether on the facts and circumsta....

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....p;   C) "Whether on the facts and in the circumstances of the case the Income Tax Appellate Tribunal was right in law in upholding the CIT(A)'s order allowing deduction under section 32AB of the Act ?" 3. The brief facts of the present case are that the assessee company is engaged in the manufacture of various chemicals products. Its main products are concentrated and diluted nitr....

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....essee had taken a loan of Rs. 15 crores from its sister concern M/s. Deepak Fertilizers & Petrochemicals Corporation Ltd. On this loan, an interest of Rs. 21,83,698/- was paid to the sister concern. The assessee was the owner of the Unit only for One month and seven days and the total amount of dividend received from the UTI amounted to Rs. 1,82,23,200/-. The assessee claimed deduction under sec. ....