2020 (3) TMI 507

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....he aforesaid terms. C.M. No. 8428/2020 (delay) 3. Issue notice. Learned counsel for the Respondent accepts notice.   4. By this application, the Appellant seeks condonation of delay 24 days in filing the appeal. Considering the extent of delay, counsel for the Respondent fairly does not oppose the application. The same is allowed and the delay is condoned. 5. The application stands disposed of in the aforesaid terms.   6. The Revenue has preferred the present appeal to assail the order dated 25.02.2019 passed by the Income Tax Appellate Tribunal (ITAT), Delhi Bench 'C', New Delhi in ITA No. 485/Del/2016 preferred by the Revenue in respect of the assessment year 2011-12. The Tribunal has dismissed the said ap....

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..... Section 44 begins with a non-obstante clause and overrides the other provisions of the Act as mentioned therein including Section 14A. We are not convinced with the submission of Mr. Ajit Sharma that Section 14A would be applicable in respect of the Respondent. Section 14A does not have independent legs to stand on. Section 14A inter alia begins with the words "for the purposes of computing the total income under this chapter, no deduction shall be allowed in respect of expenditure incurred................". The chapter in question is chapter IV. This chapter also contains the provisions relating to computation of profits and gains of business or profession. Section 44 specifically excludes the provisions of the Act relating to computatio....