TMI Blog1976 (11) TMI 117X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Since the issue involved is common, we consolidate these four appeals and dispose them of by a common order. In the assessments made for the above years the ITO had apportioned the interest and the administrative expenses and allowed proportionate amount of such expenses under the heads "business" and "other sources", overruling the assessee s claim that the entire interest and administrative e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0M of the Act should be allowed only on the "gross dividends" received by the assessee and not on the "net dividends" worked out after deducting the expenses incurred in earning the gross dividend. 3. Aggrieved by the said consolidated order of the AAC the Revenue has filed these appeals before us. The learned departmental representative contended that the AAC erred in holding that the "administ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ase and the submissions made before us. We find that the assessments under appeal are reassessments under s.147(b) for the asst. yrs. 1968-69 and 1969-70 that for the asst. yr. 1970-71 the original assessment made by the ITO was set aside by the Addl. Commissioner of income tax under s. 263 of the ITO was had passed the order under appeal on 31st Dec., 1973 and that for the asst. yr. 1971-72 the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ortion of the expenditure incurred by the assessee company in the computation of the dividend income to be charged under the head "income from other sources" and that the Addl. CIT was not correct in holding to the contrary. On the question of the admissibility of the deduction under s. 80M the Tribunal in the aforesaid order, following the rulings of certain High Court including that of the Madra ..... X X X X Extracts X X X X X X X X Extracts X X X X
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