TMI Blog2023 (1) TMI 1206X X X X Extracts X X X X X X X X Extracts X X X X ..... t of ACG Associates Capsules Pvt. Ltd. v. CIT [ 2012 (2) TMI 101 - SUPREME COURT ] had directed the A.O. to adopt the netting method. Thus we direct the A.O. to allow the netting off of interest. - ITA No.1054/Bang/2022 - - - Dated:- 19-12-2022 - Shri Chandra Poojari, AM And Shri George George K, JM Appellant by : Sri.V.Srinivasan, Advocate Respondent by : Sri.Sri.Gudimella V.P.Pavan Kumar, JCIT-DR ORDER Per George George K, JM : This appeal at the instance of the assessee is directed against the CIT(A) s order dated 12.09.2022. The relevant assessment year is 2014-2015. 2. The brief facts of the case are as follows: The assessee is a limited company engaged in the business of generation of hydroel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al Cements Ltd. (1998) 234 ITR 412 (SC) (iii) CIT v. Autokast Ltd. (2001) 116 Taxman 244 (SC) (iv) M/s.Z Square Shopping Mall (P) Ltd. in ITA No.s659, 660 661/Lkw/2013 dated 09.09.2015 (v) Kakinada SEZ (P) Ltd. v. ACIT 141 ITD 635 (Hyd.) 3. Aggrieved by the assessment order, the assessee preferred appeal before the first appellate authority. The CIT(A) confirmed the view taken by the A.O. by relying on the order of the CIT(A) in assessee s own case for assessment years 2012-2013 and 2013-2014. 4. Aggrieved by the order of the CIT(A), the assessee has filed the present appeal before the Tribunal, raising the following grounds:- 1. The orders of the authorities below in so far as they are against the appellant are oppose ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t s case deserves to be cancelled. 6. For the above and other grounds that may be urged at the time of hearing of the appeal, your appellant humbly prays that the appeal may be allowed and justice rendered and the appellant may be awarded costs in prosecuting the appeal and also order for the refund of the institution fees as part of the costs. 5. The learned AR submitted that the issue raised in ground 4 has been considered by the Tribunal in assessee s own case for assessment years 2012-2013 and 2013-2014 [ITA Nos.141 142/Hyd/2017 (order dated 09.02.2021)]. It was submitted that the Tribunal had directed the A.O. to allow set off of interest receipt with the interest expenditure. The learned AR submitted that if ground No.4 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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