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2019 (3) TMI 322 - HC - Income TaxAdmit following substantial questions of law arise for consideration. (A) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was justified in holding that the Assessing Officer had not fulfilled the pre-requirements of invoking the provisions to Explanation-3 to section 43 (1) of the Income Tax Act, 1961, and thereby allowing full claim of depreciation of ₹ 61,48,20,284/- on intangible assets worth ₹ 500 crore? (B) Whether the Income Tax Appellate Tribunal was justified in allowing carry forward of unabsorbed business losses and depreciation in the facts of this case? (C) Whether the Income Tax Appellate Tribunal was justified in confirming the order of the Commissioner (Appeals) allowing interest expenses of ₹ 40,99,56,735/- on Deep Discount Bonds (DDBs) ? (D) Whether the Income Tax Appellate Tribunal was justified in confirming the order of the Commissioner (Appeals) allowing interest expenses of ₹ 2,65,24,193/- on Optionally Fully Convertible Premium Notes (OFCPNs) ? (E) In the light of the Circular No. 2 of 2002 dated 20.3.2002 of the CBDT, whether the Income Tax Appellate Tribunal was justified in law and on facts in confirming the order of the Commissioner (Appeals) that income of Optionally Fully Convertible Premium Notes (OFCPNs) of other companies of ₹ 1,79,56,195/- was not taxable in the hands of the assessee on accrual basis ?
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