2014 (7) TMI 1224

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....O, 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 to Rs. 1,85,02,274/- u/s 2(22)(e) on account of d....

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....rs 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 emerge. i. The subsidiary company viz Doubledot Finance Limited is no....

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....ed 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 contained in section 2(18)(B), it is abundantly clear that the stipulation of "Wholly owned subsidiary" applies only....