2017 (2) TMI 34

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....stice M. R. Shah ) 1.0. As common question of law and facts arise in both these appeals with respect to different assessment years but in case of very assessee, both these appeals are decided and disposed of together by this common judgment and order. 2.0. Feeling aggrieved and dissatisfied with the impugned judgment and order passed by the learned Income Tax Appellate Tribunal dated 20.01.2016 ....

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....e Revenue, the Revenue has preferred present Tax Appeal with the following proposed question of law. "A. Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance of Rs. 2,50,85,863/made by the AO u/s. 14A of the Act ? B. Whether the Appellate Tribunal has erred in law and on facts in holding the Rule 8D does not apply to Assessment Year preceding to AY 2008-09....