TMI Blog2014 (7) TMI 506X X X X Extracts X X X X X X X X Extracts X X X X ..... ity of the facts and perusing the material available on record, the order is modified and the grounds of the appeal are redefined – Decided in favour of Assessee. - MA No.189/Ahd/2013, I.T.A. No.2066/Ahd/2010) - - - Dated:- 13-6-2014 - Shri N. S. Saini And Shri Kul Bharat,JJ. For the Petitioner : Ms. Urvashi Shodhan, AR For the Respondent : Shri A.K. Pandey, DR ORDER Per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. 3. On the contrary, ld.DR submitted that there is no mistake apparent from the record. 4. We have heard the rival submissions and perused the material available on record. We find that this Tribunal had disposed of the ITA Nos.2066/Ahd/2010 2067/Ahd/2010 for AYs 1999-2000 2000-01 respectively vide order dated 04/10/2013. It was observed by the Tribunal that the grounds for both the ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... irming the validity of the order passed u/s.143(3) r.w.s. 147 of the Act by the AO, ignoring the fact that additions are made on issues unconnected with the issue mentioned in the reason recorded for reopening. 2. The ld.CIT(A) has grossly erred in law and on facts in confirming the addition of ₹ 5,35,000/- made by AO as unexplained share application money u./s.68 of the Act. Both the low ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of A.Y. 2002-03. Appellant booked deferred revenue expenditure of ₹ 7,24,135/- and claimed 1/5th of it being ₹ 1,44,827/- as deductible u/s.35D. Both the lower authorities have failed to appreciate the submissions made by the appellant. Ld.CIT(A) ought to have deleted the disallowance made the AO. 4. Initiation of levy of interest u/s.234A, 234B and 234C of the Act is not justified. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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