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TMI Blog2021 (3) TMI 1095X X X X Extracts X X X X X X X X Extracts X X X X ..... . R. Kumar, Accountant Member: The present appeal has been filed by the revenue against the order of the ld. CIT(A), Kanpur dated 17.03.2016. 2. Following grounds have been raised by the revenue: "1. That the ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 12,44,02,301/- on account of disallowance of interest paid to M/s GNIDA as the grounds on the basis of which the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on acquiring a capital asset i.e. the lease rights of the land. 4. Aggrieved the assessee went into the appeal before the ld. CIT (A). The assessee took up the following grounds at point no. 9, 10, 11 and 12 of the grounds filed: "9. Because the AO has erroneously held that the interest paid to GNIDA is not allowable since the installments were not paid within the stipulated time and interest i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e addition, the ld. CIT (A) held as under: "I have carefully gone through the assessment order and written submissions filed by the assessee. I find force in the submissions and argument of the ld. AR. It may be seen from the facts of the case that the appellant could not pay the full value of installments to GNIDA and subsequently the authority allowed him to pay the installments but with some ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 in the appeal filed before him for which the revenue filed appeal before us. The main contention of the revenue is that the addition needs to be examined broadly in the light of allowability of the interest in acquiring the lease rights on the land but not narrowly on the issue, whether such interest is penal in nature or not. Since, the ld. CIT (A) has not adjudicated on the core of the issue, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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