2006 (11) TMI 177

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....nd in the circumstances of the case and in law, the Tribunal was right in holding that the issue being debatable, the Assessing Officer was not justified in disallowing deduction claimed by way of adjustment under section 143(1)(a) of the Income-tax Act, 1961?" At the outset, Mr. M.R. Bhatt, learned counsel for the Revenue, fairly admits that the issue is covered against the Revenue by a judgme....

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.... deductions were not permissible. It is not in dispute before us that on the date when the assessee was claiming the deductions, the judgments of the Tribunal and of the different High Courts were in favour of the assessee wherein the Tribunals or the High Courts had observed that to the extent of 40 per cent. deductions would be permissible subject to verification. We are not concerned with the j....