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TMI Blog2020 (11) TMI 881X X X X Extracts X X X X X X X X Extracts X X X X ..... : Ms. Sunita Singh, CIT(DR) ORDER PER N.K. BILLAIYA, AM ITA No. 5775/Del/2014 and ITA No. 5912/Del/2014 are cross appeals by the assessee and revenue preferred against the order of the CIT(A)-LTU, New Delhi dated 28.8.2014 pertaining to assessment year 1998-99. Both these appeals were heard together and are disposed of by this common order for the sake of convenience. 2. We will first addre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction under sections 801, 80IA and of the Act. 1.2 That on the facts and circumstances of the case and in law, the CIT(A) erred in not appreciating that the various activities/ processes undertaken by the appellant, including removal of impurities, condensate and moisture and for regulating temperature and pressure at various customer terminals, as part of mandatory contractual obligations, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ious assessment year 1997-98 vide ground No. 1 and 2 of the appeal wherein the Tribunal has followed the earlier year's decision of the coordinate bench. For our detailed discussion therein ground No. 1 with all its sub grounds are allowed. 4. We will now address to the revenue's appeal. The grievance of the revenue reads as under :- "1. on the facts and circumstances of the case and in law, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... since the disallowance was made after examining the issue and contention of the assessee was not found appropriate. 5. The appellant craves leave to, add to, alter, amend or vary from the above grounds of appeal at or before the time of hearing. " 5. Grievances raised vide ground No. 1 and 2 are identical to the findings given in ground No. 1 and 2 in assessment year 1997-98 in ITA No. 4657/ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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