2014 (7) TMI 1224

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....h O R D E R PER D. KARUNAKARA RAO, AM: This appeal filed by the Revenue on 5.3.2012 is against the order of the CIT (A)-8, Mumbai dated 26.12.2011 for the assessment year 2008-2009. 2. In this appeal, Revenue raised the following grounds which read as under: "1. On the facts and in the circumstances of the case and in law, the CIT (A) erred in deleting the addition amounting t....

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..... 4. We have heard both the parties and perused the orders of the Revenue Authorities in general and order of the CIT (A) in particular. On perusal of the said order of the CIT (A), we find the said para 4.8 is relevant in this regard and the same reads as under: "4.8. I have considered the contention of the AO as well as the Ld AR. From the above discussion, the following points emerg....

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....lic are substantially interested. v. This view is roe than amply reinforced by the cases cited by the appellant and discussed earlier in the order. vi. It is not envisaged by law that only wholly owned subsidiary of a Listed Company shall be company in which the public are substantially interested. vii. If one were to carefully consider the totality of the provision as c....