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TMI Blog2018 (8) TMI 921X X X X Extracts X X X X X X X X Extracts X X X X ..... th the impugned order passed by the learned ITAT dated 04.01.2017 passed in IAT No.939/Ahd/2002 for Assessment Year 1996-97, by which the learned Tribunal has dismissed the said appeal preferred by the Revenue, the Revenue has preferred the present Tax Appeal with the following proposed questions of law:- "[A] Whether the Appellate Tribunal has erred in law and on facts in deleting the addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... all the proposed questions. 3. The proposed Question-No.2[A] is with respect to deleting addition of Rs. 55,73,818/- made on account of opening stock. Learned CIT (Appeals) as well as learned ITAT have specifically come to a finding that the Assessing Officer was required to adopt value of opening stock for Assessment Year 1996-97 equally to the value of closing stock of 1995-96 and allowed the d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... observed by the learned Tribunal in para-51 that though the liability got settled during the year under consideration in view of the High Court's order and as the assessee followed mercantile system of accounting, the liability accrued during the year and its payment at future date cannot result in disallowance. Considering the above, the learned Tribunal has rightly deleted the aforesaid addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er. Under the circumstances, similar treatment is required to be given in the year under consideration also as rightly observed by the Tribunal. Hence, learned Tribunal has rightly confirmed the order passed by the learned CIT (Appeals), deleting addition of Rs. 63,44,823/- made on account of disallowance of interest on funds utilized for giving interest free loans to sister concerns. No substanti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enditure. As per the decision of the Hon'ble Supreme Court in the case of India Cements Ltd. (supra), the expenditure incurred on the issue of debenture is allowable expenditure and to be treated as the revenue expenditure. Under the circumstances, no error has been committed by the learned Tribunal in deleting the disallowance of expenditure on issue of nonconvertible and fully convertible debent ..... X X X X Extracts X X X X X X X X Extracts X X X X
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