2018 (9) TMI 1553

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....For the Revenue : Ms. Asima Neb, Sr. DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER, This appeal by the assessee is preferred against the order of the CIT(A) - 6, Delhi dated 30.03.2015 pertaining to A.Y 1997-98. 2. The grievances raised by the assessee read as under: "1. That the order dated 30/03/2015 in Appeal No. 265/14-15 passed by Learned CIT(A)-6, New Delhi u/s 250/154 o....

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....ed in reaffirming the reliance upon the decision of Bombay High Court in the case of Kanti Lal Chhote Lal (246 ITR 439) relied upon by his predecessor, which deals with the issue of reassortment charges forming part of business profits/turnover and not with regard to the ground of the appellant pertaining to considering net interest expenditure (if any) and prior period expenditure forming part of....

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....y that while adjudicating Ground No. 1, he has not considered all the issues raised by the assessee and, therefore, a mistake has crept as is apparent from record, which deserves rectification u/s 154/155 of the Act. The claim of the assessee was denied by the ld. CIT(A) by holding that there is no mistake apparent from record which needs to be rectified. 5. Before us, the ld. counsel for the a....

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....ting the figure of indirect cost by the Assessing Officer by including gross figure of interest instead of net figure which was supported by various judicial decisions; (ii) addition of prior period expenditure in the calculation of indirect cost by the Assessing Officer was also challenged on the plea that no portion of prior period expenditure is relatable to the export activity of the ....