2017 (9) TMI 166

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..... f the Income Tax Act, 1961 ('Act') directed by the Revenue against the order dated 6th June, 2016 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA Nos.2808/Del./2007 and 2898/Del./2007 for the Assessment Year ('AY') 2001 - 2002. 2. The short question sought to be urged in the present appeal by the Revenue is whether the ITAT erred in confirming the order of the Commissioner Income Tax .....

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..... ircumstances or the legal position requiring a different view to be taken. 5. In any event, the Court finds that the disallowances were made by the AO on ad hoc basis. As explained by this Court in CIT v. State Trading Corporation Ltd. [decision dated 17th August, 2012 in ITA No.344/2012], even prior to Rule 8D, the disallowance under Section 14 A of the Act had to be on some reasonable basis. 6 .....

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