TMI Blog2014 (6) TMI 152X X X X Extracts X X X X X X X X Extracts X X X X ..... for the purpose of computing deduction u/s section 80HHC of the and the deletion of the disallowance u/s.43B to be paid beyond the limit as provided u/s.36(1)(va) of the Act, is concerned, the decision in ACG Associated Capsules Pvt.Ltd. Vs. Commissioner of Income Tax [2012 (2) TMI 101 - SUPREME COURT OF INDIA] - Ninety per cent of not the gross interest/rent but only the net interest/rent, which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stance the order passed by the Tribunal in this case, namely, the order dated 12th November 2008 in Income Tax Appeal No.1057/M/03 and Income Tax Appeal No.1222/M/03, we are of the view that the Appeal raises substantial questions of law atleast in part. It is accordingly admitted on the following substantial questions of law. (a) Whether on the facts and in the circumstances of the case, the T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ied in relying on the decision of the Mumbai Tribunal in the case of Avaya Global Connect Ltd Vs. ACIT without appreciating that the facts in the case under consideration are quite distinguishable and cannot be compared ? 2. In so far as the exclusion of 90% of the net interest and net commission as against gross amounts under these heads from the profit of the business for the purpose of compu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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