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2020 (12) TMI 405

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..... ll process the applications/declarations in accordance with the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) and pass appropriate orders as expeditiously as possible. The assessee is given liberty to restore these appeals in the event the ultimate decision to be taken on the declarations filed by the assessee under Section 4 of the said Act is not in favour of the assessee. If such a pray .....

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..... x Act, 1961 ('the Act' for brevity) challenging the common order dated 04.9.2017 made in I.T.A.Nos.1189 and 1572/ Mds/2016 on the file of the Income Tax Appellate Tribunal, Chennai, 'B' Bench ('the Tribunal' for brevity) for the assessment year 2011-12. 2. The assessee has filed these appeals by raising the following substantial questions of law: TCA.No.306 of 2018 .....

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..... nces of the case, the Income Tax Appellate Tribunal was right in law in upholding the disallowance of expenditure made on proportionate basis to the rental income even though the appellant had service apartment business, income from which was assessed as business income ? TCA.No.307 of 2018 : i. Whether, on the facts and in the circumstances of the case, the Income Tax Appellate Tribun .....

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..... would amount to double disallowance i.e once under Section 24 of the Act and again under Section 14A of the Income Tax Act, 1961 read with Rule 8D of the Income Tax Rules, 1962? iv. Whether the provisions of Section 14A of the Income Tax Act, 1961 read with Rule 8D of the Income Tax Rules, 1962 would be attracted even if there is no expenditure incurred in connection with exempt income earn .....

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..... ision to be taken on the declarations filed by the assessee under Section 4 of the said Act is not in favour of the assessee. If such a prayer is made, the Registry shall entertain the prayer without insisting upon any applications to be filed for condonation of delay in restoration of the appeals and on such request made by the assessee by filing miscellaneous petitions for restoration, the Regis .....

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