TMI Blog2017 (4) TMI 112X X X X Extracts X X X X X X X X Extracts X X X X ..... ramed in the appeal when filed but also further evidenced by the fact that there is no ground specifying any grievances with regard to the impugned order's finding in respect of Section 40(ba) of the Act. The residuary ground in the appeal memo has also proceeded on the basis that the order is not sustainable for the grounds mentioned earlier, which in turn are all related to Section 40(a) (ia) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tribunal erred in deleting the addition of ₹ 4,99,19,593/pertaining to salaries, made by the Assessing Officer and confirmed by CIT(A), on account of disallowance u/s. 40(ba)? (b) Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in deleting the addition of ₹ 2,39,64,463/pertaining to administrative expenses, made by the Assessing Officer an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the amount of ₹ 2,39,64,463/are also contractual payments under section 194C and thus hit by provisions under section 40(a)(ia)? (b) Whether in the facts available on record and the law applicable to those facts, the order of the Tribunal led to a perverse interpretation of those facts and the law applicable to those facts? (c) Any other question of law that this Hon'ble C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d earlier, which in turn are all related to Section 40(a) (ia) of the Act. 5 In view of the objections raised by Mr. Padvekar, Mr. Ahuja, learned Counsel for the Revenue seeks time to consider the objections and respond to the same, including taking appropriate action, if so necessary. 6 At the request of Mr. Ahuja, the appeal adjourned to 10th April, 2017. - - TaxTMI - TMITax - Income ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
