2021 (7) TMI 114

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....lde;ATARAJ RÃNGASWAMY APPELLANTS: SRI K V ARAVIND, ADVOCATE RESPONDENT: SRI M LAVA, ADVOCATE JUDGMENT The present Income tax Appeal is arising out of the order dated 9.5.2014 passed in ITA.No.1341/Bang/2012 by the Income Tax Appellate Tribunal, Bengaluru. 2. This Court after hearing he learned counsel for the parties has framed the following substantial questions of law; ....

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....1.4.2013 relevant Assessment Year 2013-14? 3. Whether on the facts and in the circumstances of the case of Tribunal was correct in accepting the additional ground raised regarding applicability of Section 115JB without appreciating that the assessee has neither raised the issue before the Assessing Officer or before the Appellate Commissioner and the assessee itself in it's return of inco....

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....hat the assesee is entitled to deduction under section 80IA of the Act without setting off of the loss of loss-making units against the profits of the profit - making units, without taking into consideration that deduction is provided to the eligible business and not for an undertaking? 2. Whether on the facts and in the circumstances of the case, the tribunal was correct in holding that ....

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....by a Division Bench of this Court vide judgment dated 19.01.2015 in I.T.A.No.778/2009, whereas, substantial question of law No.2 is answered by another Division Bench of this Court vide judgment dated 16.01.2020 in ITA.No.18/2014. Accordingly, substantial question of law No.3 does not survive. 4. In view of the preceding analysis, no substantial questions of law arise for consideration in....