2018 (5) TMI 1166

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..... 3,76,36,870/= ?" [B] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made on account of the Guarantee fee charges of Rs. 8,62,37,606/= ?" [C] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made on account of interest on Loan to Zydus France of Rs. 13,44,042 ?" [D1] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made under Section 40[a](i) on account of non deduction of TDS u/s.195 of the Act in respect of payment of commission to non-resident ?" [D2] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made under Section 40 [a](i) on account of non dedu....

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....ting the addition of disallowance under Section 14A to added back for computation of Book Profit under Section 115JB ?" Questions [A], [B], [C], [D1], [E], [F], [G] and [I] arise for our consideration. Tax Appeal is, therefore, admitted for consideration of these substantial questions of law :- [A] "Whether the Appellate Tribunal has erred in law and on facts by deleting the addition made on account of Benchmarking of Convertible Loan of Rs. 3,76,36,870/= ?" [B] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made on account of the Guarantee fee charges of Rs. 8,62,37,606/= ?" [C] "Whether the Appellate Tribunal has erred in law and on facts in deleting the addition ....