2019 (4) TMI 978

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..... Respondent. ORDER P. C. :­ 1. The Revenue is in Appeal against the Judgment of the Income Tax Appellate Tribunal raising the following questions for consideration. "(i) Whether on the facts and circumstances of thet case and in law, the Hon'ble ITAT was justified in restricting the disallowance under Rule 8D(2)(iii) to Rs. 2 Lakhs in each year on 'adhoc basks' without appreciating that Se .....

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..... of.  The Revenue contends that once the disallowance is made in terms of Rule 8D, the Tribunal cannot provide for an ad­hoc formula.  We, however, notice that the amount involved is not substantial and the discussion contained in the Judgment of the Tribunal would essentially point to the fact whether such disallowance at all was justified in view of sub­Section (2) of Section 14 .....

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..... lectricity is goods within the meaning of the Sales Tax Act and the Excise Act.  We do not find any reason to interfere with the view of the Tribunal. We make is clear that we have not examined the first contention of the Assessee in this respect namely additional depreciation under Section 32(1)(iia) would be available on installation of new plant and machinery, whether the same is for the p .....

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