2019 (3) TMI 1676

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.... Singh, DR For the Respondent : Shri Farooq Irani, AR ORDER PER MAHAVIR SINGH, JM: The only common issue in this two Misc. Applications of Revenue is that there is a mistake apparent from record in ITAs No. 1178/Mum/2013 & 5879/Mum/2012, wherein it is alleged that the Tribunal has dismissed the Revenue's appeal by observing that the AO has not recorded satisfaction while making disallowance un....

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....epresentative, relied on the Misc. petition and referred to Para 4 and 5 of the Misc. Petition which is common in both the years and the same read as under: - "4. However, the AO, at Para 5 of the assessment order dated 29.12.2011 had rejected the amount offered for disallowance by the assessee, for the reason that it was not in accordance with Rule 8D. 5. Thus, the AO has recorded a satisfact....