2016 (3) TMI 1316

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....AR Respondent by : Smt. Sonia Kumar Sr. D.R. ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER: 1. These two appeals by two different assessees are directed against two separate orders of the ld. CIT(A)-II, Surat dated 06.10.2015. 2. As both these appeals involve common issues, these were heard together and are disposed of by this common order for the sake of convenience. 3. The common ....

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.... taxes thereon provisions of Section 40(a)(ia) are not applicable because of the amendment brought in the explanation. However, this claim of the assessee did not find favour with the A.O, who was of the firm belief that the amendment is applicable from A.Y. 2013-14 onwards and accordingly made the disallowance of interest. 6. Assessee carried the matter before the ld. CIT(A) but without any su....

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....nch, Vishakhapatnam in the case of Merilyn Shipping & Transports vs. Addl. CIT. The Circular also refers to the decision of the Hon'ble High Court of Gujarat, High Court of Allahabad which all relates to the issue relating to "paid or payable" whereas the issue before us relates to the amendment of second proviso to Section 40(a)(ia) which has been held to have a retrospective effect by the Hon'bl....