TMI Blog2015 (6) TMI 679X X X X Extracts X X X X X X X X Extracts X X X X ..... of computing deduction under section 10A, 10B, 80IC and 80IB of the Income Tax Act, 1961? Whether on the facts and in the circumstances of the case the Tribunal ought to have held that no adjudication in terms of Section 145(2) of the Act can be made in respect of that part of the purchase price that represented the cenvat credit available on the goods purchased by the appellant as the same wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and above what had already been allocated by the appellant was required to be further allocated for the purposes of computing deduction under section 10A, 10B, 80IC and 80IB of the Income Tax Act, 1961? (B) Whether the Tribunal ought to have allowed the provision for retirement pension of ₹ 81.56 crores as claimed? (C) Whether the Tribunal ought to have allowed the retirement pension o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ought to have held that no adjudication in terms of Section 145(2) of the Act can be made in respect of that part of the purchase price that represented the cenvat credit available on the goods purchased by the appellant as the same was not a duty that was paid or incurred by the appellant? (Reframed during the course of hearing.) 3. Question 'B' and 'C' are not pressed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essing Officer by giving an opportunity to the Assessee. Similar observations are found in the impugned order in respect of payment of non-compete fees of ₹ 4.75 crores to M/s MUL Dentpro (P) Ltd. Thus ex facie there is contradiction in the above observations found the impugned order. It is clarified that the Assessing Officer would consider the issue on remand without being influenced in a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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