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PR CIT Versus Citi Financial Consumer Finance India Ltd.

Disallowance of loan acquisition costs - Disallowance of expenditure incurred on the issue of non convertible debentures and commercial papers by considering it to be deferred revenue expenditure - ITAT allowed asessee's case - Held that:- Although a statement has been made in the memorandum of appeal that appeals are "learned to have been filed” in this Court by the Revenue in respect of the ITAT's orders for AYs 2003-04 and 2004-05, Mr N. P. Sahni, learned Senior Standing Counsel, candidly sta .....

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sis of the statement made on behalf of the Assessee that, till date there is no information regarding any appeals having filed by the Revenue in respect of the orders of the ITAT for the earlier said AYs.

The Court notices that in respect of other items of expenditure incurred by the Assessee for AYs 2001-02 and 2002-03, for e.g., the expenditure incurred on advertisement and publicity, the stand of the Revenue that they should be treated as deferred revenue expenditure was not accept .....

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against revenue. - ITA No. 682/2015 - Dated:- 28-9-2015 - S. Muralidhar And Vibhu Bakhru, JJ. For the Petitioner : Mr N P Sahni, Senior Standing Counsel with Mr Nitin Gulati, Junior Standing Counsel For the Respondents : Mr C S Aggarwal, Senior Adv. With Mr Prakash Kumar, Adv ORDER 1. This appeal by the Revenue is directed against the impugned order dated 20th February, 2015 passed by the Income Tax Appellate Tribunal (' ITAT') in ITA No.4776/Del/2010 for Assessment Year ('AY') 2 .....

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e Assessee, has placed before the Court a compilation of the orders of the ITAT in the appeals concerning the Assessee for the earlier years i.e. AY. 2003-04, 2004-05 and 2005-06. In particular, he has drawn attention to the findings of the ITAT in those years on these two very issues where the stand of the Assessee has been accepted by the ITAT. He states that, as of date, the Assessee has not received any information about any appeal having been filed by the Revenue against the orders of the I .....

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