2016 (3) TMI 973

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.... Ms. Samiksha Kanani, Adv ORDER P. C. At the request of the counsel, the Petition is being disposed of finally at the stage of Admission. 2. This Petition under Article 226 of the Constitution of India challenges the order dated 6.1.2016 passed under Section 254(2) of the Income-tax Act, 1961 (Act) by the Income-tax Appellate Tribunal (Tribunal). The impugned order rejects the Petitioner's....

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....he Tribunal were as under: "1.(a) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the disallowance u/s 14A, r.w. Rule 8D, made by the AO. (b) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that the disallowance suomoto offered by the assessee was reasonable as it was based on scientific working. 2. O....

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....s as under: "1(a) On the facts and in the circumstances of the case as well as in law, the Ld. CIT (A) erred in deleting the disallowance u/s. 14A r.w. Rule 8D, made by the AO. 1(b) On the facts and in the circumstances of the case as well as in law, the Ld. CIT(A) erred in holding that the disallowance suomoto offered by the assessee was reasonable as it was based on scientific working. 2. O....

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....ance u/s.14A to Rs. 1,08,11,971/- for the purpose of computing Book Profit u/s.115JB of the Act." It is on this revised grounds of appeal, that the rectification application of the Petitioner has been disposed of. 6. It is further grievance of the Petitioner that the revised grounds of appeal on the part of the Revenue which find place in the impugned order of the Revenue's appeal were neve....