2022 (2) TMI 103

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.... Per R.S. Syal, VP These two appeals by the Revenue relating to the assessment years 2011-12 and 2012-13 emanate from the common order dated 28.02.2018 passed by the ld. CIT(A). Since the issues raised in these appeals are identical, we are, therefore, proceedings to dispose them off by this consolidated order for the sake of convenience. 2. The grievance of the Revenue is against the dire....

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....gs arising, out of application u/s. 154, did not accept the contention of the assessee. The ld. CIT(A), however, allowed the assessee's claim. Aggrieved thereby, the Revenue has come up in appeal before the Tribunal. 4. We have heard the rival sides in Virtual court and gone through the relevant material on record. It is seen that the AO, in his order u/s. 143(3), did not accept the assesse....

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....lowing Foreign Tax credit in respect of interest income offered during the year under consideration, we uphold the impugned order on this score. 5. The facts for the assessment year 2012-13 are admittedly mutatis mutandis similar to the immediately preceding year. For this year also, the AO did not allow credit for Tax credit on interest income credited by the foreign entity. The assessee moved....