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2019 (5) TMI 19 - ITAT DELHIRectification u/s 154 - disallowance made u/s 14A - debatable issue - whether order of CIT (A) is erroneous and is not tenable on facts and in law deleting the addition of disallowance made u/s 14A to the book profit - HELD THAT:- CIT (A) has deleted the addition by following the decision rendered by Hon’ble Supreme Court in the case of Volkart Brothers – [1971 (8) TMI 3 - SUPREME COURT] and CIT vs. RTCL Ltd. [2012 (4) TMI 287 - DELHI HIGH COURT] on the ground that when the issue is debatable section 154 cannot be invoked. Since the ld. CIT (A) has deleted the addition by following the settled principle of law that when issue is debatable one section 154 cannot be invoked to make further addition, we find no illegality or perversity in the impudent order passed by the ld. CIT (A), hence appeal filed by the Revenue is dismissed.
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