2007 (1) TMI 543

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....y order dated 13-10-2006, after hearing counsel for both parties, the following substantial questions of law were framed by the Court in the present appeal for consideration :           "1. Whether ITAT was legally correct in holding that assessee is entitled to reduce interest paid by it from the interest received, by it while calculating deduction ....

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....90 per cent of the interest for computing deduction under section 80 HHC. 3. In the appeal by the Department to the ITAT the ground urged in this regard, (as set out in para 3 of the impugned order dated 17-3-2006 of the ITAT) related "to calculation of deduction under section 80HHC." Clearly no challenge was made to the finding of the Assessing Officer that the interest income was business inc....