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2014 (8) TMI 123 - HC - Income TaxDisallowance u/s 40A(8) borrowings were taken for the purpose of payment of tax - Held that:- Following the decision in Hindustan Cocoa Products Ltd. v/s Commissioner of Income Tax, reported in [1998 (11) TMI 115 - BOMBAY High Court] - the benefit of section 80V would be available to the Assessee if the borrowings were taken for the purpose of payment of tax - the deposits were primarily taken for the payment of taxes Decided against Revenue. Interpretation of Rule 6D Re-computation of disallowance expenditure incurred by the Assessee in connection with the travel of an employee - Held that:- Following the decision in Commissioner of Income Tax v/s AOROW India Ltd., reported in [1997 (7) TMI 92 - BOMBAY High Court] - the Assessee had incurred certain expenditure in connection with the travel of its employees including hotel expenses and allowance ITO computed the disallowance out of expenditure u/s 37(3) of the Act r.w Rule 6D - the ITO took into account the total expenditure incurred by each employee in each trip undertaken by him - CIT (A) held that the disallowance under Rule 6D should be worked out by taking into consideration all the trips undertaken by the employee during the year together and not on the basis of each trip Decided in favour of Revenue.
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