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58 results for “TDS”+ Section 205clear

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Key Topics

Section 143(3)45Section 14A44Section 194H44Section 201(1)41Section 14834TDS27Disallowance21Deduction20Section 143(1)19Section 147

VODAFONE MOBILE SERVICES LTD.9 ( FORMERLY KNOWN AS VODAFONE SOUTH LTD NOW MERGED WITH VODAFONE MOBILE SERVICES LIMITED),CHENNAI vs. ITO (TDS) WARD 1(6), CHENNAI

In the result, both the appeals filed by the assessee as well as the Revenue are dismissed

ITA 1534/CHNY/2018[2008-09]Status: DisposedITAT Chennai18 May 2020AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos.1348 & 1349/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 The Assistant Commissioner Of M/S. Vodafone South Ltd., Income Tax, Vs. (Now Known As Vodafone Mobile Services Ltd.), Tower-I, 9Th Floor, Tds Circle – 3, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. [Pan: Aabcb5847L] आयकर अपील सं./I.T.A. Nos.1534 & 1535/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 M/S. Vodafone Mobile Services Ltd., Vs. Income Tax Officer (Tds), [Formerly Known As Vodafone Ward I(6), South Ltd.] Tower-I, 9Th Floor, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Salil Kapoor, Advocate, : Ms. Soumya Singh, Advocate & Shri Ketan Ved, C.A. ""थ" की ओर से/Respondent By : Shri A. Sundararajan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.03.2020 घोषणा की तारीख /Date Of Pronouncement : 18.05.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: These Cross Appeals Filed By The Revenue As Well As The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 02.02.2018 Relevant To The Assessment Years 2008-09 & 2009-10. Since Common Ground Has Been Raised By The Same Assessee, Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity.

For Respondent: Shri A. Sundararajan, Addl. CIT
Section 194HSection 200

Showing 1–20 of 58 · Page 1 of 3

18
Addition to Income18
Section 153A13
Section 201(1)
Section 201(3)
Section 201(3)(i)
Section 203

TDS. Once it is held that the right to service can be sold then the relationship between the assessee and the distributor would be that of principal and principal and not principal and agent. The terms of the agreement set out supra in unmistakable terms demonstrate that the relationship between the assessee and the distributor is not that of principal

VODAFONE MOBILE SERVICES LTD.9 ( FORMERLY KNOWN AS VODAFONE SOUTH LTD NOW MERGED WITH VODAFONE MOBILE SERVICES LIMITED),CHENNAI vs. ITO (TDS) WARD 1(6), CHENNAI

In the result, both the appeals filed by the assessee as well as the Revenue are dismissed

ITA 1535/CHNY/2018[2009-10]Status: DisposedITAT Chennai18 May 2020AY 2009-10

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos.1348 & 1349/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 The Assistant Commissioner Of M/S. Vodafone South Ltd., Income Tax, Vs. (Now Known As Vodafone Mobile Services Ltd.), Tower-I, 9Th Floor, Tds Circle – 3, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. [Pan: Aabcb5847L] आयकर अपील सं./I.T.A. Nos.1534 & 1535/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 M/S. Vodafone Mobile Services Ltd., Vs. Income Tax Officer (Tds), [Formerly Known As Vodafone Ward I(6), South Ltd.] Tower-I, 9Th Floor, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Salil Kapoor, Advocate, : Ms. Soumya Singh, Advocate & Shri Ketan Ved, C.A. ""थ" की ओर से/Respondent By : Shri A. Sundararajan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.03.2020 घोषणा की तारीख /Date Of Pronouncement : 18.05.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: These Cross Appeals Filed By The Revenue As Well As The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 02.02.2018 Relevant To The Assessment Years 2008-09 & 2009-10. Since Common Ground Has Been Raised By The Same Assessee, Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity.

For Respondent: Shri A. Sundararajan, Addl. CIT
Section 194HSection 200Section 201(1)Section 201(3)Section 201(3)(i)Section 203

TDS. Once it is held that the right to service can be sold then the relationship between the assessee and the distributor would be that of principal and principal and not principal and agent. The terms of the agreement set out supra in unmistakable terms demonstrate that the relationship between the assessee and the distributor is not that of principal

ACIT TDS CIRCLE 3, CHENNAI vs. VODAFONE SOUTH LTD., CHENNAI

In the result, both the appeals filed by the assessee as well as the Revenue are dismissed

ITA 1348/CHNY/2018[2008-09]Status: DisposedITAT Chennai18 May 2020AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos.1348 & 1349/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 The Assistant Commissioner Of M/S. Vodafone South Ltd., Income Tax, Vs. (Now Known As Vodafone Mobile Services Ltd.), Tower-I, 9Th Floor, Tds Circle – 3, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. [Pan: Aabcb5847L] आयकर अपील सं./I.T.A. Nos.1534 & 1535/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 M/S. Vodafone Mobile Services Ltd., Vs. Income Tax Officer (Tds), [Formerly Known As Vodafone Ward I(6), South Ltd.] Tower-I, 9Th Floor, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Salil Kapoor, Advocate, : Ms. Soumya Singh, Advocate & Shri Ketan Ved, C.A. ""थ" की ओर से/Respondent By : Shri A. Sundararajan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.03.2020 घोषणा की तारीख /Date Of Pronouncement : 18.05.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: These Cross Appeals Filed By The Revenue As Well As The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 02.02.2018 Relevant To The Assessment Years 2008-09 & 2009-10. Since Common Ground Has Been Raised By The Same Assessee, Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity.

For Respondent: Shri A. Sundararajan, Addl. CIT
Section 194HSection 200Section 201(1)Section 201(3)Section 201(3)(i)Section 203

TDS. Once it is held that the right to service can be sold then the relationship between the assessee and the distributor would be that of principal and principal and not principal and agent. The terms of the agreement set out supra in unmistakable terms demonstrate that the relationship between the assessee and the distributor is not that of principal

ACIT TDS CIRCLE 3, CHENNAI vs. VODAFONE SOUTH LTD., CHENNAI

In the result, both the appeals filed by the assessee as well as the Revenue are dismissed

ITA 1349/CHNY/2018[2009-10]Status: DisposedITAT Chennai18 May 2020AY 2009-10

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos.1348 & 1349/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 The Assistant Commissioner Of M/S. Vodafone South Ltd., Income Tax, Vs. (Now Known As Vodafone Mobile Services Ltd.), Tower-I, 9Th Floor, Tds Circle – 3, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. [Pan: Aabcb5847L] आयकर अपील सं./I.T.A. Nos.1534 & 1535/Chny/2018 िनधा"रण वष"/Assessment Years:2008-09 & 2009-10 M/S. Vodafone Mobile Services Ltd., Vs. Income Tax Officer (Tds), [Formerly Known As Vodafone Ward I(6), South Ltd.] Tower-I, 9Th Floor, Chennai. Tvh Beliciaa Towers, Block 94, Nrc Nagar, Chennai 600 028. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Salil Kapoor, Advocate, : Ms. Soumya Singh, Advocate & Shri Ketan Ved, C.A. ""थ" की ओर से/Respondent By : Shri A. Sundararajan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.03.2020 घोषणा की तारीख /Date Of Pronouncement : 18.05.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: These Cross Appeals Filed By The Revenue As Well As The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 02.02.2018 Relevant To The Assessment Years 2008-09 & 2009-10. Since Common Ground Has Been Raised By The Same Assessee, Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity.

For Respondent: Shri A. Sundararajan, Addl. CIT
Section 194HSection 200Section 201(1)Section 201(3)Section 201(3)(i)Section 203

TDS. Once it is held that the right to service can be sold then the relationship between the assessee and the distributor would be that of principal and principal and not principal and agent. The terms of the agreement set out supra in unmistakable terms demonstrate that the relationship between the assessee and the distributor is not that of principal

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 755/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Sept 2017AY 2014-15

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 754/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Sept 2017AY 2012-13

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1644/CHNY/2014[2010-11]Status: DisposedITAT Chennai21 Sept 2017AY 2010-11

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 377/CHNY/2015[2014-15]Status: DisposedITAT Chennai21 Sept 2017AY 2014-15

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1414/CHNY/2014[2011-12]Status: DisposedITAT Chennai21 Sept 2017AY 2011-12

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 2804/CHNY/2014[2011-12]Status: DisposedITAT Chennai21 Sept 2017AY 2011-12

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 376/CHNY/2015[2013-14]Status: DisposedITAT Chennai21 Sept 2017AY 2013-14

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1415/CHNY/2014[2010-11]Status: DisposedITAT Chennai21 Sept 2017AY 2010-11

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

205 of 2005 and 44 others, which includes, Vodafone, Idea Cellular, Bharti Hexacom, Tata Teleservices, etc. dated 11.07.2017 considered the similar issue with regard to TDS under section

M/S POTHYS,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(3), CHENNAI

The appeal is allowed

ITA 1360/CHNY/2023[2020-21]Status: DisposedITAT Chennai15 May 2024AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No. 1360/Chny/2023 (िनधा"रणवष" / Assessment Year: 2020-21) M/S. Pothys, Vs. The Deputy Commissioner Of No.15, Dr.Nageswara Rao Road, Income Tax, T. Nagar, Central Circle 1(3), Chennai – 600 017. Chennai. [Pan: Aaffp 2437B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjun Raj, Advocate For Shri Y. Sridhar, Ca ""यथ" क" ओर से /Respondent By : Shri Ar.V. Srinivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 09.05.2024 घोषणा क" तारीख /Date Of Pronouncement : 15.05.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri AR.V. Srinivasan, Addl. CIT
Section 143(3)Section 200Section 206Section 206CSection 234ESection 37Section 91

TDS statement. The revenue is right in contending that Section 234(E) of the Act is meant to ensure that assessee files the statement in time, so that the Department can clear the returns of thepersons connected with the assessee, i.e., from whom tax has been deducted at source without any delay and accurately with increasing or overloading the burden

SHRI. S. SATHYARAJ,CHENNAI vs. ACIT,NON CORPORATE CIRCLE 10(1), CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 1529/CHNY/2023[2020-21]Status: DisposedITAT Chennai30 Apr 2024AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1529/Chny/2023 िनधा"रण वष" / Assessment Year: 2020-21 Shri. S. Sathyaraj, Assistant Commissioner Of No. 13A, Brahadambal Road, V. Income Tax, Nungambakkam, Non Corporate Circle 10(1), Chennai – 600 034. Chennai – 600 034. [Pan: Aafps-6100-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. J. Chandrasekaran, Ca ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 16.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 30.04.2024 आदेश /O R D E R

For Appellant: Shri. J. Chandrasekaran, CAFor Respondent: Shri. D. Hema Bhupal, JCIT
Section 143(1)Section 143(1)(a)Section 154Section 201(1)Section 205

TDS of INR 2,50,000 as the Appellant is not at fault for non- :-2-: ITA. No: 1529/Chny/2023 payment of tax deducted by the deductors to the Government account. 3. The Lower Authorities have erred in not following the provisions of Section 205

KARTHIK LAKSHMAN,CHENNAI vs. IYO, INTL TAXATIONWARD-1(2), CHENNAI

In the result, appeal of the assessee is allowed

ITA 2182/CHNY/2025[2024-25]Status: DisposedITAT Chennai30 Jan 2026AY 2024-25

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2182/Chny/2025 िनधा"रण वष" /Assessment Year: 2024-25

For Respondent: Ms. R.Kavitha, Addl. CIT
Section 143(1)Section 205Section 250

205 of the Act action of the respondent in not giving the credit of the tax deducted at source for which form no.16 A have been produced by the assessee - deductee and consequently impugned demand notice issued under Section 221(1) of the Act cannot be sustained. Concerned respondent therefore, is required to be directed to give credit

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1671/CHNY/2014[2007-08]Status: DisposedITAT Chennai28 Dec 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

section 40a(ia) of the Act are not applicable and deleted the addition. The Ld. CIT(A) discussed deduction u/s. 36(1)(viia) of the Act and on and relied on the assessee's own case for the assessment year 2013-14 in ITA No. 1485/2007 in remitting to the Assessing Officer to follow jurisdictional Tribunal decision and allowed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1804/CHNY/2014[2010-11]Status: DisposedITAT Chennai28 Dec 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

section 40a(ia) of the Act are not applicable and deleted the addition. The Ld. CIT(A) discussed deduction u/s. 36(1)(viia) of the Act and on and relied on the assessee's own case for the assessment year 2013-14 in ITA No. 1485/2007 in remitting to the Assessing Officer to follow jurisdictional Tribunal decision and allowed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1801/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

section 40a(ia) of the Act are not applicable and deleted the addition. The Ld. CIT(A) discussed deduction u/s. 36(1)(viia) of the Act and on and relied on the assessee's own case for the assessment year 2013-14 in ITA No. 1485/2007 in remitting to the Assessing Officer to follow jurisdictional Tribunal decision and allowed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1802/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

section 40a(ia) of the Act are not applicable and deleted the addition. The Ld. CIT(A) discussed deduction u/s. 36(1)(viia) of the Act and on and relied on the assessee's own case for the assessment year 2013-14 in ITA No. 1485/2007 in remitting to the Assessing Officer to follow jurisdictional Tribunal decision and allowed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1803/CHNY/2014[2009-10]Status: DisposedITAT Chennai28 Dec 2016AY 2009-10

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

section 40a(ia) of the Act are not applicable and deleted the addition. The Ld. CIT(A) discussed deduction u/s. 36(1)(viia) of the Act and on and relied on the assessee's own case for the assessment year 2013-14 in ITA No. 1485/2007 in remitting to the Assessing Officer to follow jurisdictional Tribunal decision and allowed