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2020 (4) TMI 547 - HC - Income TaxAddition of CENVAT receivable made u/s 145A - HELD THAT:- ADMIT following substantial question of law arises for consideration - Whether on the facts and in the circumstances of this case, the Income Tax Appellate Tribunal was justified in upholding the deletion of addition of CENVAT receivable on ₹ 2,98,57,398/- made under section 145A of the Income Tax Act, 1961? Disallowance u/s 14A read with rule 8D - assessee suo moto disallowed expenditure incurred for earning exempt income, on the ground that the assessee had not provided the fund flow statement - HELD THAT:- As assessee had suo motu disallowed the amount of ₹ 20,25,500/-, being the expenditure incurred for earning exempt income, which was 8.50% of such income, it is not possible to state that there is any infirmity in the impugned order passed by the Tribunal upholding the order of the Commissioner (Appeals) qua this ground of appeal. Proposed question [B], therefore, does not give rise to any question of law. Disallowance of provision of doubtful debts u/s 36(1)(vii) - HELD THAT:- In the light of the fact that the Commissioner (Appeals) has merely applied the decision of the Supreme Court in the case of CIT v. Vijaya Bank [2010 (4) TMI 46 - SUPREME COURT] to the facts of the present case and directed the Assessing Officer to ascertain the entitlement of the benefit of deduction under section 36(1)(vii) of the Act, no infirmity can be said to have been committed qua this ground of appeal so as to give rise to any question of law. Accordingly, this ground of appeal is also rejected.
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