TMI Blog2012 (3) TMI 565X X X X Extracts X X X X X X X X Extracts X X X X ..... R P.C. This appeal arises from a decision of the Income Tax Appellate Tribunal dated 11 January 2007 in relation to Assessment year 1989-90. The following questions of Law have been raised by the Revenue: A) Whether on the facts and in the circumstances of the case, and in law, the Hon ble Tribunal was justified in law in holding that share issue expenses are attributable to acquisition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he dividend, interest, rent and profit on sale of assets should not be reduced from the business profits for the purpose of deduction u/s. 32AB of the Income Tax Act; D) Whether on the facts and in the circumstances of the case and in law, the Hon ble Tribunal was justified in law in holding that the assessee is entitled to the deduction in respect of enhanced liability of ₹ 282.76 lacs b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... question C would stand governed against the Revenue by the decision rendered today in Income Tax Appeal No.1023 of 2009 for Assessment Year 1988-89. In view of the statement no substantial question of law would arise. As regards question B the Assessee made a payment of ₹ 4,86,000/- to Glaxo Sports Club. The Assessing Officer brought the entire reimbursement/contribution under Section 40A(9) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... visions of Section 40A(9) are not attracted. The view of the Tribunal is supported by the Judgment of the Division Bench in Commissioner of Income Tax Vs. Bharat Petroleum Corporation Ltd. 252 ITR Page 43. In the circumstances, no substantial question of law would arise. 3 As regards question E the Tribunal has accepted the case of the Assessee in Para 41 of its decision that in view of the rev ..... X X X X Extracts X X X X X X X X Extracts X X X X
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