2007 (1) TMI 590

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....after hearing counsel for both parties, the following only substantial question of law was framed for determination by this Court (in place of the earlier order dated 19-4-2006) : "Whether ITAT was correct in law in holding that the assessee was entitled to reduce interest paid by it against interest received by it while calculating deduction under section 80HHC read with Explanation (baa) ....

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....e's claim for netting. However, in the light of the order of the Special Bench cited above, the order of the Income-tax authorities rejecting the principle of netting cannot be upheld. While therefore upholding the assessee's claim for netting of the interest. We restore the matter to the Assessing Officer to enable him to examine the assessee's claim that there is factually a nexus between the in....