THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. M/S. NUMALIGARH REFINERY LTD., GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. M/S. NUMALIGARH REFINERY LTD., GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. M/S. NUMALIGARH REFINERY LTD., GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 03, GUWAHATI vs. NUMALIGARH REFINERY LIMITED, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

NUMALIGARH REFINERY LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 03, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

19,83,895/- (8) Disallowance of claim of deduction for Interest paid u/s 234D of the Income Tax Act,1961.“ Interest on excess refund” Ground and Assessment Year Amount Ground No.(3 ) for the Assessment Year 2011- 12 ; Rs. 3,83,88,266/- Ground No.(2) for the Assessment Year 2012- 13; Rs. 6,54,39,202/- Ground No.(2

M/S. G.D. MARKETING PRIVATE LIMITED,GUWAHATI vs. INCOME TAX OFFICER, WARD-2(1), GUWAHATI`

In the result, the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Sanjay Garg

19, 2021 Date of pronouncing the order :April 30, 2021 ORDER The present appeal filed by the assessee is directed against the orderdated 08.08.2019of the Commissioner of Income Tax (Appeals), Guwahati [hereinafter referred to as the ‘CIT(A)]. The assessee in this appeal has taken the following grounds of appeal: “1. For that the Ld. CIT(A) erred

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA vs. M/S. BROOKE BOND INDIA LIMITED, MUMBAI

In the result, appeal of the revenue and the cross-objection of the assessee are dismissed

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Ble]

disallowance of Rs. 2,19,13,300/- should be reduced to 67,13,000/-. 2. The action of the Assessing Officer is not in accordance with the provisions of law and the judicial pronouncement made by the Supreme Court and the High Courts. Section

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, DIBRUGARH vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH. vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH. vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

OIL INDIA LTD.,,DIBRUGARH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH.

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, DIBRUGARH vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

OIL INDIA LTD.,DIBRUGARH vs. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE -2, DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2

OIL INDIA LTD.,DIBRUGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE -2, DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

disallowance. Mr. Jain took us to page 214 in the assessee’s paper book comprising of its Form 10CCB audit report (revised) making it clear that it had in fact raised sec. 80IB(4) deduction claim than sec. 80IB(a) (supra) of the Act. Page 219 (internal page 6) thereafter also contains the assessee’s specific response to clause “2