2012 (9) TMI 1266

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....ndent : Mr. Atul K. Jasani PC: This appeal by the revenue under Section 260A of the Income Tax Act,1960 ("the Act") challenges the order dated 22/11/2011 of the Income Tax Appellate Tribunal ("the ITAT") arising out of ITA No. 3407/Mum/2006 for the for the assessment year 2002-03. 2) Being aggrieved, the revenue has formulated the following questions of law for the consideration by this C....

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....as raised at a very late stage and the rejection thereof by the Assessing officer was not challenged before any appellant authority till date? C) Whether on the facts and in the circumstances of the case and in law the ITAT was justified in deciding the issue of applicability of Section 50 of SIDBI Act raised by the assessee for the first time before the High Court of Bombay by filing an ....

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....tand taken in ITA Nos. 6671/Mum/2008 and 7143/Mum/2009 dated 15/2/2012 wherein the ITAT "I" Branch, Mumbai held that According to Section 50 of the SIDBI Act, SIDBI was exempted from Income tax till the amendment under section 142 of the Finance Act, 2001 which deleted the section 50 of the SIDBI Act with effect from 1st April, 2002 i. e. A.Y. 2002-03 due to this amendment by way of deletion of se....