MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

In the result the appeal of the revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

condone delay in filing of appeals and admit the appeals filed by the revenue for adjudication. 3. The brief facts of the relevant assessment years are as under: 3.1 A.Y. 2015-16: The brief facts emanating from the records are that the assessee is a HUF, engaged in the business of Renting out properties and also received interest income

SARAVANA REALITY PRIVATE LIMITED,CHENNAI vs. DCIT CENTRAL CIRCLE 3 (4), CHENNAI

In the result, appeal filed by the assessee is allowed for

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.No.696 & 697/Chny/2018 ("नधा"रणवष" / Assessment Year: 2007-08 & 2013-14 ) M/S. Saravana Realty Pvt.Ltd Vs The Deputy Commissioner Of Kgs Corporate House, Income Tax, 63, Kamaraj Avenue Road 1St Street, Central Circle-3(4) Adyar,Chennai-600 020. Chennai-600 034. Pan: Aakcs0474R (अपीलाथ"/Appellant) (""यथ"/Respondent)

251 ITR 864 (Delhi )(FB). In the present case, the Commissioner has: for the purpose of enhancement, relied not on any material which was before the Assessing Officer while making the assessment under appeal before him nor on any material seized during the search attracting the provisions of section 153C, but on the basis of an entry in the bank

ITO, NCW - I (4),, CHENNAI vs. M/S. NITHYASUDHA COMBINES,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.576 & 577/Chny/2020 िनधा"रण वष"/Assessment Year: 2015-16 & C.O. Nos. 06 & 07/Chny/2021 [In I.T.A. No. 576 & 577/Chny/2020] The Income Tax Officer, Vs. M/S. Nithyasudha Combines, Non Corporate Ward 1(4), No. 8/20, Second Cross Street, Chennai – 600 034. Nandanam Extension, Nandanam, Chennai 600 085. [Pan: Aakfn6811A] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By : Shri R. Venkata Raman, C.A. सुनवाई की तारीख/ Date Of Hearing : 25.04.2022 घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai, Both Dated 16.12.2019 Relevant To The Assessment Year 2015-16 Passed Against Deletion Of Quantum Addition Made Under Section 68 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Deletion Of Penalty Levied Under Section 271(1)(C) Of The Act. The First

condoning the delay in filing the appeal. Thus, the ground raised by the Revenue is dismissed. 6. The next ground raised in the ground Nos. 5 to 9 relates to violation of Rule 46A of the Income Tax Rules, 1962 by stating that Income-tax Non Statutory Form-51 [ITNS-51] is not sufficient. 6.1 We have considered the rival

ITO, NCW - I (4),, CHENNAI vs. M/S. NITHYASUDHA COMBINES,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.576 & 577/Chny/2020 िनधा"रण वष"/Assessment Year: 2015-16 & C.O. Nos. 06 & 07/Chny/2021 [In I.T.A. No. 576 & 577/Chny/2020] The Income Tax Officer, Vs. M/S. Nithyasudha Combines, Non Corporate Ward 1(4), No. 8/20, Second Cross Street, Chennai – 600 034. Nandanam Extension, Nandanam, Chennai 600 085. [Pan: Aakfn6811A] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By : Shri R. Venkata Raman, C.A. सुनवाई की तारीख/ Date Of Hearing : 25.04.2022 घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai, Both Dated 16.12.2019 Relevant To The Assessment Year 2015-16 Passed Against Deletion Of Quantum Addition Made Under Section 68 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Deletion Of Penalty Levied Under Section 271(1)(C) Of The Act. The First

condoning the delay in filing the appeal. Thus, the ground raised by the Revenue is dismissed. 6. The next ground raised in the ground Nos. 5 to 9 relates to violation of Rule 46A of the Income Tax Rules, 1962 by stating that Income-tax Non Statutory Form-51 [ITNS-51] is not sufficient. 6.1 We have considered the rival

RASIPURAM VIVEKANANDA EDUCATIONAL TRUST,RASIPURAM vs. ITO, EXEMPTION WARD,, SALEM

In the result, appeals filed by the assessee are allowed for statistical\npurposes

delay of 48 days in filing the appeals, which was condoned.", "held": "The Tribunal found that the CIT(A)'s directions amounted to an enhancement of income without following the procedure laid down in Section 251

KANCHAN BAI,CHENNAI vs. ITO NCW 5(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao

Section 49(1) of the Act, the period of holding the asset has to be determined by including the period for which the said asset was held by the previous owner, then obviously in arriving at the indexation, the first year in which the said asset was held by the previous owner would be the first year for which

KANCHANA BAI CHORDIA ,CHENNAI vs. ITO CW 5(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao

Section 49(1) of the Act, the period of holding the asset has to be determined by including the period for which the said asset was held by the previous owner, then obviously in arriving at the indexation, the first year in which the said asset was held by the previous owner would be the first year for which

TIRUPUR SOUTH ROTARY CHARITABLE TRUST,COIMBATORE vs. ACIT, EXEMPTIONS,, COIMBATORE

In the result, all the grounds of appeal raised by the assessee are allowed for statistical purposes

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1553/Chny/2025 Assessment Years: 2022-23 Tirupur South Rotary Charitable Trust, Assistant Commissioner Of South Rotary Hall, Income Tax (Exemptions), Opp Nataraja Theatre, Tirupur, Coimbatore. Coimbatore, Tamil Nadu-641 604. [Pan: Aaett0308E] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri S.Bhupendran, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri P.Krishna Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 12.08.2025 घोषणा की तारीख /Date Of Pronouncement : 13.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

Section 11 of the Act. Consequently, the exemption claim cannot be entertained. The appellant has stated that Form 10B was not filed within the stipulated time due to the illness of its Chartered Accountant, who was handling the compliance requirements. Medical reports have been furnished to substantiate this claim. Given these circumstances, the appellant has requested that the delay

ACIT CORPORATE CIRCLE 6 (2), CHENNAI vs. M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED, CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 6 (2), CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

ACIT CORPORATE CIRCLE 6(2), CHENNAI vs. SUNDARAM BNP PARIBAS HOME FINANCE LTD., CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

SUNDARAM BNP PARIBAS HOME FINANCE LTD,CHENNAI vs. DCIT, CORP CIR -6(2), CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

ACIT CORPORATE CIRCLE 6 (2), CHENNAI vs. M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED, CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

ACIT CORPORATE CIRCLE 6 (2), CHENNAI vs. M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED, CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 6 (2), CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

ACIT CORPORATE CIRCLE 6 (2), CHENNAI vs. M/S SUNDARAM BNP PARIBAS HOME FINANCE LIMITED, CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

SUNDARAM BNP PARIBAS HOME FINANCE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income

ACIT, CHENNAI vs. SUNDARAM BNP PARIBAS HOME FINANCE, CHENNAI

In the result, all these appeals filed by the assessee and

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपीलसं./I.T.A.Nos.1888/Chny/2018, 929, 2149 & 2150/Chny/2019 ("नधा"रणवष" / Assessment Years: 2013-14 To 2016-17) M/S. Sundaram Bnp Paribas Home Vs The Deputy Commissioner Of Finance Ltd., Income Tax, Sundaram Towers, 46,Whites Road Corporate Circle-6(2) Chennai-600 014. Chennai-34. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./I.T.A.Nos.3219 & 1513/Chny/2018, 301, 829, 2077 & 2078/Chny/2019 ("नधा"रणवष" / Assessment Years: 2011-12, 2013-14, 2012-13, 2014-15 To 2016-17) Vs M/S. Sundaram Bnp Paribas The Assistant / Deputy Commissioner Of Income Tax, Home Finance Ltd., Corporate Circle-6(2) Sundaram Towers, Chennai-34 46,Whites Road Chennai-600 014. Pan: Aadcs 4826J (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay in filing of these two appeals is condoned and appeals filed by the assessee & the Revenue are admitted for adjudication. 5. The Revenue has raised more or less common grounds of appeal for all assessment years, however, major issues challenged by the Revenue for all assessment years are disallowance of deduction u/s.36(1)(viii) of Income