2023 (12) TMI 1457

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....el. Appeal admit on the following substantial question of law. QUESTION OF LAW b) Whether on the facts and circumstances of the case and in law the Hon'ble ITAT erred in holding that strategic investments should not be considered for making disallowance under Section 14 read with Rule 8D(2)(iii) without appreciating the fact that no such distinction exists in the Income Tax Act and that income....