In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes
Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]
801A has to be allowed with reference to the gross total income' and not the 'business income' alone. Further Reliance in this regard is also placed on the decision of Bombay High Court in the case of V.M. Salgaocar & Brother (P.) Ltd Vs CIT (81 taxmann.com 357) involving similar facts as involved in the appellant's case. In the decided