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2018 (3) TMI 671 - HC - Income TaxAddition of interest expenditure for its exempt unit at Baddi - assessee had wrongly proportioned the interest for the exempt unit vis-a-vis the non-exempt units - Held that:- In Control and Switchgear Ltd. (2014 (6) TMI 46 - DELHI HIGH COURT), the Court utilized the formula because the assessee could not indicate– in the facts of that case, the actual figures relatable to interest expenditure. In both the cases, the ITAT and the CIT(A) have considered the assessee’s explanations and concluded that it was in a position to indicate that the concern could in fact allocate interest-free funds that enabled it to gain substantial relief. There is no error, therefore, in the findings. So far as the grievance with respect to CIT(A)’s permitting the assessee to file a second or fresh application – Form 10CCB, the Court holds that there is no error of law per se and that the Revenue’s contention on this score could have been aired or agitated before the ITAT.
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