TMI Blog2019 (3) TMI 363X X X X Extracts X X X X X X X X Extracts X X X X ..... t only net interest income could be included, namely, gross interest minus expenditure incurred on the borrowal of the amount for investment for earning that interest and such net interest alone could be considered for the purpose of Section 80HHC and, if that net figure is so taken, there is no question of disallowance to the extent of 90% of the negative figure of net interest we are of the opin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessment Years 2000-2001 and 2001-2002 respectively, dismissing the appeals of the Assessee. 2. The learned Tribunal, in the said order, recorded the concession given by the learned counsel for the Assessee in terms of the decision of the Hon'ble Supreme Court in the case of Ipca Laboratories v . Deputy Commissioner of Income Tax , 266 ITR 521, on the issue whether the word ' P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re is so taken, there is no question of disallowance to the extent of 90% of the negative figure of net interest. According to the learned counsel, the said aspect has not been considered by the learned Tribunal in the order impugned, though a specific ground was raised before it in the appeal. 4. Having heard the learned counsel for the parties and also on perusal of the impugned order of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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