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Dy. CIT-Range-8 (3) , Mumbai. Versus Syntel Limited Mumbai

2015 (9) TMI 897 - ITAT MUMBAI

Computation of deduction under Section 10A/ 10B - CIT(A) reducing from the profits of the business eligible for deduction under Section 10A/ 10B an amount on account of recoveries of under- utilised dedicated human resources - Held that:- Tribunal while adjudicating the issue in the AY.2002-03 decided the matter as undisputedly, the expenses incurred by the assessee on account of export of computer software are much higher than the amount of ₹ 81.91 crores received by the assessee from the .....

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above in this order, clearly indicates that the reimbursement of expenses are nothing but directly linked with the business of the assessee. - Decided in favour of the assessee.

Reducing from the profits of the business eligible for deduction under Section 10A/10B an amount in respect of recovery of Global Recruitment Cell(GRC)cost - Held that:- Identical issue is decided in favour of the assessee by the order of the Tribunal for the AY.2002- 03 - Decided in favour of the assessee. < .....

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es.In view of the above facts and circumstances of the case, we hold that the provisions of sec.10A(7) are not applicable on the facts of the present case. Accordingly, this ground of the assessee is also allowed.

Not considering the claim that the interest income derived from the industrial undertaking - not allowing deduction u/s 10A/10B of the Act in respect of the said interest income - Held that:- his issue is also covered in favour of the assessee by the decision of the Tribunal .....

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ofit for the year under appeal after debiting exchange loss of about ₹ 6.51 crores in the P&L account and after reducing the export turnover amount by ₹ 6,51,30,323/-. In the earlier year the AO had not accepted the similar position when there was gain because of exchange rate.The assessee, before the FAA stated that the issue for the earlier years was pending for adjudication, that the AO should be directed to modify the order after the issue was adjudicated by higher authorities. T .....

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o basis for Assessing Officer’s exclusion of the above receipts from computation of business profit as the assessee has not claimed the expenditure in its P & L Account and these amounts are netted off in the respective expenditure accounts and only the net expenditure related to the assessee’s business were claimed in the P & L Account. In view of this we are of the opinion that the order of the CIT(A), who analysed the factual matrix of the assessee’s claims and arrived at the correct conclusi .....

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re is no legal infirmity in the order of the FAA.Therefore, confirming his order,we decide ground no.2 against the AO. - Decided in favour of assessee.

Disallowance u/s 14A - Held that:- We find that the assessee earned dividend income of ₹ 13,870/-,that the FAA made a disallowance of ₹ 54.49 lakhs,that the AY.under appeal is prior to AY.2008-09.In pursuance of the judgment of Hon’ble Bombay High Court,we hold that provisions of Rule 8D of the Income tax Rules,1962 are app .....

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1/Mum/2010, ITA No.6589/Mum/2011, ITA No.6742/Mum/2011, ITA No.6885/Mum/2012 - Dated:- 31-8-2015 - Sh. A.D. Jain and Rajendra, JJ. For The Assessee :Shri Dinesh Vyas-(AR) For The Revenue : Shri Manjunatha Swamy-CIT-(DR) PER RAJENDRA, AM Challenging the orders of the CIT (A)-,Mumbai,the Assessee and the Assessing Officers(AO.s.) have filed cross appeals and have raised following grounds of appeal for the above mentioned Assessment Years(AY.s.) ITA No.3413/Mum/2007-AY.03-04,(Appeal by the Assessee .....

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The Appellant prays that the JCIT be directed not to reduce from the profits of the business eligible for deduction under Section 10A/10B of the Act the amount of ₹ 15,18,65,460 on account of recoveries of under-utilised dedicated human resources. II 1. On the facts and in the circumstances of the case, the learned CIT(A) erred in confirming the action of the JCIT in reducing from the profits of the business eligible for deduction under Section 10A/10B of the Act an amount of ₹ 9,71 .....

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ked by the JCIT after holding that general observations cannot be made with regard to the profit margins shown by the Appellant and comparison of industry average profits to determine the ordinary profits was not a fair criterion adopted by the JCIT. 2. The Appellant prays that it be held that no disallowance under Section 10A/10B of the Act was warranted by invoking the provisions of Section 10A(7) of the Act. IV 1. On the facts and in the circumstances of the case, the learned CIT(A) erred in .....

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der and deal with the said additional ground of appeal raised during the course of proceedings before CIT(A). V 1. On facts and in the circumstances of the case, the learned CIT(A) erred in not directing the JCIT to follow a consistent view in respect of treatment of exchange loss amounting to ₹ 6,51,30,323 for computing export profit eligible for deduction u/s 10A/10B of the Act. 2.The Appellant prays that the JCIT be directed that in the event of final resolution of the disputed issue in .....

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(A) erred in directing the Assessing Officer to restrict the disallowance for purpose of deduction u/s.10A/10B of the Act to ₹ 9,71,653/-out of total recovery of ₹ 5,00,44,259/- and delete the addition in respect of the remaining amount of ₹ 4,90,72,606/-(Rs.5,00,44,259 ₹ 9,71,653) 2. On the facts and in the circumstances of the case in law, the CIT(A) erred in directing to allow deduction on delayed payment of employer and employee's contribution to P. F made within .....

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i ('the CIT(A)') legally erred in upholding the action of the Addl. Commissioner of Income Tax, Range 8(3), Mumbai (the Addl.CIT). In reducing the profits of the business eligible for deduction under section 10A/ 10B/ 80HHE of the Act an amount of ₹ 16,90,05,755 on account of recoveries of under-utilised dedicated human resources. 2.The Appellant prays that the Addl.CIT be directed not to reduce from the profits of the business eligible for deduction under section 10A/10B/80HHEof t .....

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allow deduction of expenses from recoveries of under utilized human resources of ₹ 16,90,05,755. III 1. On the facts and in the circumstances of the case, the learned CIT(A) erred in confirming the action of the Addl.CIT in reducing from the profits of the business eligible for deduction under section 10A/ 10B/ 180HHE of the Act an amount of ₹ 5,68,902 out of ₹ 5,84,67,872 in respect of recovery of Global Recruitment Cell (GRC) cost. 2. The Appellant prays that the Addl.CIT be .....

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7; 28,266/- and interest on loan to employees ₹ 1,92,398/- on the ground that these income are not derived from export of computer software. 2. The appellant prays that the Addl.CIT be directed to consider interest on income-tax refund of ₹ 49,19,769/-, interest on security deposit of ₹ 28,266/- and interest on loans to employers of ₹ 1 ,92,398/-, as derived from export of computer software and grant deduction under section.10/A/10B/80HHEof the Act. V 1. On facts and in t .....

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mony with the final order of adjudication. VI 1. The Appellant craves leave to add, alter, or withdraw all or any of the above Grounds of Appeal and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing. ITA No.2263/Mum/2008, Assessment Year-2004-05(Appeal by the AO): 1. "On the facts and in the circumstances of the case and in law, the CIT(A) erred in directing the A.O to restrict the disallowance to ₹ 5,68,902/- and del .....

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acts and in the circumstances of the case and in law, the Ld.CIT(A) erred in directing the A.O to allow deduction u/s.l0A & 10B on interest income of ₹ 3,06,63,052/-being interest of EEFC account and deposit with bank as margin money, without appreciating the facts of the case." ITA No.7391/Mum/2010-AY.2006-07(Appeal by the AO): "1.On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing ₹ 10,07,15,209/- as profits eligible for deductio .....

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ndertaking and the decision of the Hon'ble ITA T, 'E' Bench, Mumbai in the case of Tricom India Limited vs. ACIT 36 SOT 302, wherein it is held that interest income is not eligible for deduction u/s.10A 10B." The Appellant prays that the order of the CIT(A) on the above ground be set aside and that of the ITO/ ACIT /DCIT be restored. The Appellant craves leave to amend or alter any grounds or add a new ground which may be necessary. ITA No.6589/Mum/2011,AY.2007-08(Assessee s app .....

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e circumstances of the case, the learned CIT(A) erred in upholding the action of the AO of not granting the deduction under Section 10A/10B, which is consequent to the addition made to the Business Income of the units claiming such deduction, as the profits of the business units are eligible for deduction under Section 10A/ 10B of the Act. The Appellant prays that the AO be directed to grant deduction under Section 10A/10B after considering the addition made to the income. 3.Without prejudice to .....

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t or before the appeal hearing. ITA/6742/Mum/2011.AY.,2007-08(AO s appeal) "1.On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing interest income of ₹ 11,90,24,116/- as profits eligible for deduction u/s.10A 10B though the same were not derived from export of computer software without appreciating the facts of the case." 2.On the facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating the ratio of the judg .....

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the order of the CIT(A) on the above ground be set aside and that of the ITO/ ACIT /DCIT be restored. The Appellant craves leave to amend or alter any grounds or add a new ground which may be necessary. ITA/6885/Mum/2012.AY.,2008-09(AO s Appeal) "1. On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing interest income of ₹ 14,2819,778/- as profits eligible for deduction u/s.10A 10B though the same were not derived from export of computer software w .....

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in the case of Tricom India Limited vs. ACIT 36 SOT 302, wherein it is held that interest income is not eligible for deduction u/s.10A 10B." The Appellant prays that the order of the CIT(A) on the above ground be set aside and that of the ITO/ ACIT /DCIT be restored. The Appellant craves leave to amend or alter any grounds or add a new ground which may be necessary. Assessee-compnay,engaged in the business of development and export of computer software services,was formed in May 1992. Detai .....

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0 21,00,40,670/- 12.07.2011 2008-09 31.03.2009 21,00,34,749/- 08.12.2010 21,00,40,670/- 12.07.2011 ITA/3413/Mum/2007-/AY.2003-04: 2.First Ground of appeal is about reimbursement of cost of underutilized dedicated human resources for the purpose of deduction u/s. 80A of the Act.During the course of hearing before us the representatives of both the sides agreed that the issue was decided in favour of the assessee by the order of the Tribunal delivered in assessee s own case for AY.02-03(ITA/3859/ .....

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sions and considered them carefully.After considering the submissions and perusing the relevant material on record,we find that the claim of the assessee is allowable.The AO disallowed the claim of the assessee on the reasons that receipt of ₹ 18, 91, 72,279/- are of revenue in nature and they are not entitled for exemption u/s 10A of the Act because these receipts were not derived by the undertaking from the export of computer software. It has been mentioned by the AO that in other words, .....

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s stated that these receipts do not have direct nexus to the computer software; however, he failed to establish that how these receipts are not directly linked with the export of computer software and on what account these receipts have been received by the assessee. If the contention of the ld AO is accepted that these are revenue receipts, in that case also these receipts have to be treated as receipts on account of export of computer software because the assessee deals in this business with t .....

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ssee is entitled for deduction u/s 10A because these receipts are directly linked with the business of the assessee. Various decisions relied upon by the assessee before the CIT(A), which have been discussed by the CIT(A) in his order and also reproduced somewhere above in this order, clearly indicates that the reimbursement of expenses are nothing but directly linked with the business of the assessee. 12 In the case of Dunlop Rubber Co Ltd in 141 ITR 493 (Cal), the Hon'ble Calcutta High Cou .....

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ses so recovered were inextricably related to the execution of projects of Syntel Inc/Syntel Europe. The facts of the present case are similar to the facts of the case of Dunlop Rubber Company Ltd. Therefore, in view of the decision of the Hon'ble Calcutta High Court it has to be held that the receipts on account of reimbursement are nothing but reduction of expenses incurred by the assessee on the project executed on behalf of the Syntel Inc. /Syntel Europe as per clauses of the agreement. .....

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e assessee,part of which was reimbursed as per agreement.On account of reimbursement the expense burden of the assessee has been reduced,which resulted increase in profit. The increased profit on account of reimbursement of expenses is nothing but profit derived out of the business of the assessee company; therefore, the assessee company is eligible for exemption. 13 In view of the above facts and circumstances and without going into details further, we hold that the assessee is eligible for exe .....

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ction 10A/10B of the Act an amount of ₹ 9,71,653 out in respect of recovery of Global Recruitment Cell(GRC)cost.It was brought to our notice that the identical issue is decided in favour of the assessee by the order of the Tribunal for the AY.2002- 03 (supra).We find that the Tribunal had linked the issue with the issue of under utilization of human resources and had held as under: 14.Ground no. 5 relates to disallowance of ₹ 9,73,398/- on account of recovery of Global Recruitment Ce .....

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A(7) of the Act.Before us,it was agreed by the Representatives of both the sides that the tribunal had decided the issue in favour of the assessee,while adjudicating the appeal filed by the assessee for the AY.02-03(supra).We would like to reproduce the relevant paragraph of the said order: Ground No 6 relates to applicability of provisions of sec.10A(7). This ground is also linked with the ground No.4.Ground No.4 we have disposed in favour of the assessee by which it has been held that the asse .....

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ain of other players in the same industry, such comaprison cannot be made with average profit margin of the same industry. This is because, the average would necessarily be depressed by taking into account the lower profits made by some of the other players. In the case of appellant AR has given various reasons as to how and why its profit margins are better than the industry average. Appellant is having 100% export turnover and it has no interest cost. AR has also stated that its depreciation c .....

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7; 18,91,93,126/-and ₹ 9,73,398/- out of ₹ 3,11,20,944/-.In view of above discussion, however, since addition of ₹ 3,01,47,546/-(Rs.3,11,20,944 ₹ 9,73,398)has been deleted, profits to that extent would increase in view of the above, no separate adjudication is considered necessary on this issue. The CIT(A) has not given any finding because of the reason that he has dismissed the ground no.4, we have allowed in favour of the assessee and in view of the reasoning given by t .....

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pplicable on the facts of the present case. Accordingly, this ground of the assessee is also allowed. Respectfully,following the above referred order of the Tribunal,we decide Ground no.3 in favour of the assessee. 5.Next ground is about not considering the claim that the interest income aggregating to ₹ 5, 40,69,769/-derived by the assesseewas derived from the industrial undertaking and not allowing deduction u/s 10A/10B of the Act in respect of the said interest income.Before us,it was a .....

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exemption u/s. 10A and 10B of the Act, we find that this issue is also covered in favour of the assessee by the decision of the Tribunal in assessee s own case for the AYrs. 99-2000 and 2000-01 wherein it has been held to have a direct nexus with the business and development of export of software. Respectfully following the decisions of the coordinate bench, these grounds of the assessee are allowed. Respectfully following the above order of the Tribunal and considering the fact-that the appeal .....

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6.51 crores in the P&L account and after reducing the export turnover amount by ₹ 6,51,30,323/-. In the earlier year the AO had not accepted the similar position when there was gain because of exchange rate.The assessee, before the FAA stated that the issue for the earlier years was pending for adjudication, that the AO should be directed to modify the order after the issue was adjudicated by higher authorities. The FAA was of the opinion that the assessee should not have any grievance .....

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7AY-2003-04(Appeal by the AO): 7.First ground of appeal,filed by the AO,deals with restricting the disallowance for purpose of deduction u/s.10A/10B of the Act to ₹ 9,71,653/-out of total recovery of ₹ 5,00,44,259/- and deleting the addition in respect of the remaining amount of ₹ 4,90,72,606/-.During the assessment proceedings,the AO found that the assessee had shown total recovery of ₹ 5 Crores and had claimed deduction of the said amount u/s.10 of the Act.He was of the .....

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Court while filing appeal for the AY.2005-06. 7.2.We are of the opinion that the issue,regarding eligibility for the deduction u/s. 10 A/10B of the Act,has attained finality,as the department had accepted the order of the Tribunal for the identical issue in the AY.2005-06.We would like to reproduce the relevant part of the order of the Tribunal for the that AY.(supra)and same reads as under: 2.Revenue has raised the following two grounds: 1. On the facts and in the circumstances of the case and .....

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ed the CIT(A) has erred in granting deduction under section 10A on the amount of expenditure reimbursement as it has no direct nexus with the assessee export activity and it being an independent concern of the assessee following the principles laid down by the Hon'ble Supreme Court in the case of Liberty India 317 ITR 218 (SC) the amount cannot be considered as derived from the export activity for the purpose of section 10A/10B. It was further submitted that receipts are not part of the expo .....

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ished by the Hon ble Supreme Court in the above referred case. 4.The learned counsel in reply, however, submitted that the issue is not that of independent concern or claim of 10A. He referred to the order of the A.O. and also to the order of the CIT(A), particularly para 3.6 to submit that the assessee was never charged the expenditure to the P & L Account. It has separately accounted for the expenditure incurred on behalf of the foreign companies in its books and the expenditure was reimbu .....

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'ble Bombay High Court and has accepted the orders of the ITAT. Even the issue which was contested before the Hon'ble High Court was also dismissed, which is on the foreign exchange gains for the purpose of section 10A. In view of the above it was submitted that the orders of the CIT(A) are to be upheld. 5.We have considered the issue. After considering the submissions and perusing the relevant material on record we find that the order of the CIT(A) is to be upheld. The order is as under .....

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alaries, welfare, telephone, travelling, vehicle etc and claimed that these expenses have been shared with M/s. Syntel Inc and M/s Syntel Europe on actual time sharing basis and there is no profit markup. This aspect of appellant s case was also examined by the Addl. CIT (Transfer Pricing-II), Mumbai. It is seen from the order u/s. 92CA(3) of the Act of the above assessment year passed by the Addl. CIT, Mumbai that the AO [Transfer Pricing-II] has observed that the basis of allocation, that is t .....

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ncurred on behalf of M/s. Syntel Inc. and other entities are tracked separately and recovered at the end of the month from the respective entities on actual basis without any markup. In view of the detailed examination of facts, my predecessor had decided this ground in favour of the appellant for A.Y. 2002-03. During the course of appellate proceedings, the appellant has also filed the copy of the order of ITAT, E-bench in ITA No. 3534/Mum/06 dated 06.01.2009 for A.Y. 2002-03 in appellant s own .....

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tion under section 10A/10B on the gross receipts netted off in the respective accounts after obtaining the details of the ledger copies and excluding the same from computation. It was the submission that this amount was reimbursement on cost to cost basis for the services provided to the other group concerns. There is no basis for Assessing Officer s exclusion of the above receipts from computation of business profit as the assessee has not claimed the expenditure in its P & L Account and th .....

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ings of the ITAT even though that order was taken up in appeal on another issue, which also was dismissed. In view of this there is no merit in the Revenue s ground. Accordingly the same is dismissed. Following the above,we decide ground no.1 against the AO. 8.Second ground is about directing the AO to allow deduction on delayed payment of employer and employee's contribution to P. F made within grace period.The AO had not allowed the claim made by the assessee with regard to payment of empl .....

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owing deduction u/s. 10A/10B of the Act. 9.1.While deciding the ground no.1,filed by the AO for the year under appeal,we have decided the issue in favour of the assessee.Following the orders of the Tribunal for AY.2002-03 (supra),on the issue before us,we dismiss ground no.3 raised by the AO. ITA No.1069/Mum/2008, AY.-2004-05: 10.Following our order on the issues of under-utilised dedicated human resources,GRC cost and the eligibility of interest income for claiming deduction u/s.10A/10B of the .....

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e identical issue decided by it for the AY.2005-06 and have decided ground no.1 against the AO.Following our order for the AY.2003-04(at paragraph no. 7 to 7.2)we dismiss both the grounds raised by the AO for the year under appeal. 12.Last ground raised by the AO is about calculation of interest income for deduction u/s.10A/ 10B of the Act.We find that while deciding the issue of eligibility of interest income for the earlier year and in the appeal filed by the assessee for the year under consid .....

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tion claimed u/s.10A/10B of the Act.In the orders of the earlier AY.s.,we have adjudicated the issue of calculation of interest income for deduction u/s.10A/10B and decided that same in favour of the assessee.Following the same,ground no.2 is decided against the AO. ITA/6589/Mum/2011-/AY.2007-08: 15. Grounds no.1 & 3 deal with disallowance made by the AO u/s.14 A of the Act.During the assessment proceedings,the AO found that assessee had shown to have held the investments of ₹ 18.09 la .....

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f the average value of investment.He made a disallowance to ₹ 5,950/-. 15.1.Aggrieved by the order of the AO the assessee preferred an appeal before the FAA.It was pointed out by the assessee that there was an arithmetical error in the calculation made by the AO,that following the method adopted by the AO the disallowance should be have been 54,49,923/-.After considering the submissions of the assessee,he held that rule 8D of the Income tax Rules,1962 was applicable.He directed the AO to c .....

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