2011 (3) TMI 1706

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....NT  MR JP SHAH WITH MR MANISH J SHAH FOR  THE RESPONDENT ORAL ORDER (Per : HONOURABLE MR.JUSTICE AKIL KURESHI) 1. Revenue is in appeal against the judgment of Income-Tax Appellate Tribunal raising following questions:- "[A] Whether the Appellate Tribunal was justified in upholding the order of the CIT(A) in deleting the disallowance of Rs. 5,76,41,612/- on account of....

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....t to the first question, Tribunal confirmed the view of the CIT(Appeals) and considered that the assessee was receiving subsidy from the Government. Such subsidy was worked out taking into account the interest component also. Justification for including interest component was presented before the Tribunal in the form of paper book. The Tribunal, therefore, concluded that it would be incorrect to h....

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....of the fact that the assessee was involved in public distribution system of issuing items such as food grains for citizens, particularly, below poverty line. In course of such transactions, the assessee received certain subsidies from the Government, which also took into account the interest component on the amounts loaned between the parties. When the Income-Tax Authority as well as the Tribunal ....