TMI Blog2015 (9) TMI 1631X X X X Extracts X X X X X X X X Extracts X X X X ..... ly, 2015 did not arise for consideration before the AO. Since such contention was not raised by the Revenue before the AO, the Respondent Assessee had no occasion to be heard on such issue at the appropriate stage. The Court, therefore, cannot permit the Revenue to urge the said issue at this stage. Moreover, the Respondent Assessee is stated to have a deficit of ₹ 33,67,78,348 for the AY ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the repayment of loan of ₹ 46 lakhs should be treated as application of income is disallowed because the loan was never taken as income at the time of receipt . 2. Therefore, the question that the Revenue seeks to urge in this appeal, and on which notice was issued by this Court on 10th July, 2015 did not arise for consideration before the AO. Since such contention was not raised b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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