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2009 (8) TMI 1193

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....CCOUNTANT MEMBER :- 1. This is an appeal filed by the revenue against the order of the Learned Commissioner of Income Tax(Appeals)-I, Surat, dated 7.5.04. 2. Ground No. 1 of the appeal reads as under: "1. On the facts and in the circumstances of the case and in law, the Learned Commissioner of Income Tax(Appeals), Surat has erred in directing to delete the disallowance of ₹ 17,20,403/- ....

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....arned Assessing Officer disallowed the deduction claimed by the assessee on the ground that M/s. Motilon Synthetics is an associate concern of the assessee and Section 40A(2)(b) is attracted, and that assessee had not furnished details regarding the services provided. 4. In appeal, the Learned Commissioner of Income Tax(Appeals) allowed the claim for deduction to the assessee observing as under: ....

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....erefore prayed that the order of the Learned Commissioner of the Income Tax(A), Surat be set aside and that of the Learned Assessing Officer be restored." 6. The brief facts of the case are that the Learned Assessing Officer disallowed interest paid to sister concern amounting to ₹ 79,692/- on the ground that the assessee has made interest free advances to its sister concerns diverting the....