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2017 (10) TMI 1636 - AT - Income TaxAddition u/s 14A in the computation of book profit u/s 115JB deleted - Disallowance u/s 14A upholded partly in the computation of income under the normal provisions by deleting the addition made rule 8D(2)(ii) and sustaining the addition under rule 8D(2)(iii) - granting additional depreciation under clause (iia) read with clause (ii) of section 32(1) - Addition of `Depletion’ in excess of the rates specified in Schedule XIV of the Companies Act, 1956, deleted in the computation of `book profit’ u/s 115JB - remitting the matter of TPA from the international transaction of payment for intra group services to the AO/TPO for fresh adjudication - remitting to the AO/TPO the transfer pricing addition on account of interest on redeemable preference shares of Cairn India Ltd. recharacterised as unsecured loan advanced to the AE, for a fresh decision- directing to allow credit for TDS and advance tax after verification. HELD THAT:- We set aside the impugned order and remit the matter to the file of Assessing Officer/TPO for deciding the issues raised in the grounds taken for the instant year in conformity with the view taken by the Tribunal in its order for assessment year 2011-12 [2017 (10) TMI 588 - ITAT DELHI], as has been briefly set out above. Assessee has raised fresh grounds on interest u/s 234B and u/s 234C. It was admitted that interest u/s 234B is consequential. As regards interest u/s 234C, we direct that the same be computed with reference to the returned income and not the assessed income. Appeal is allowed for statistical purposes.
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