2015 (4) TMI 1041

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....nt Thakkar i/b PDS Legal for the Respondent. P.C. : 1. This appeal of the Revenue challenges the order dated 8th August, 2012, passed by the Income Tax Appellate Tribunal, Mumbai. There were two Income Tax Appeals before the Tribunal, one by the Revenue and the other by the assessee. The assessment year was 1997-98. 2. Mr. Tejveer Singh appearing for the Revenue submits that the substanti....

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.... and not on net basis did not really arise from the assessment or the assessment order. In that regard we find that the Tribunal in its order particularly at page 102 onwards has found that the said question and pertaining to the allowability of expenditure incurred in respect of earning dividend and interest income liable to tax at special rate under section 115A was, in any event, covered and ag....