2021 (11) TMI 216

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....or the Respondents : S. Srinivas, CIT-DR ORDER Per S.S. Godara, JM This assessee's appeal for AY. 2009-10 arises from the CIT(A)-1, Guntur's order dated 18-09-2019 passed in case No. 0407/2014-15, involving proceedings u/s. 143(3) of the Income Tax Act, 1961 [in short, 'the Act']. Heard both the parties. Case file perused. 2. The assessee raises the following substan....

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....h Explanation-2 under sub-section (3) of section 10A of the Act. e. The Ld. CIT(A) ought to have appreciated that as per RBI Circular no. 33 dated 28.02.2007 the RBI has delegated power of approval to ING Vysya Bank which in turn has approved WE LLS FARGO BANK in which the amount of Rs. 42,86,17,492/- has been credited. f. The Ld. CIT(A) ought to have appreciated that the Hon&#39....

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....lopment proceeds of Rs. 42,86,17,492/- are reduced from the total turnover also, there won't be any disincentive, in spite of the fact that the same amount has been included in the total turnover of Rs. 48,08,54,127/- as adopted by him in his computation of deduction u/s. 10A of the Act. j. Without prejudice to other grounds, the Ld. CIT(A) ought to have reduced the amount of Rs. 42,8....