IN THE HIGH COURT OF DELHI AT NEW DELHI
13.
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ITA 598/2006
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COMMISSIONER OF INCOME TAX ..... Appellant
Through Ms.P.L.Bansal, Advocate.
.
versus
.
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ESCORTS FINANCE LTD ..... Respondent
Through Mr.R.M.Mehta, Advocate.
.
.
CORAM:
HON'BLE MR. JUSTICE VIKRAMAJIT SEN
HON'BLE DR. JUSTICE S. MURALIDHAR
.
.
O R D E R
28.11.2006
Admit.
Following substantial questions of law arise for consideration:
?1. Whether the Tribunal was justified in law in deleting the addition of
Rs.3,38,30,000/- made on account of provisions debited by the assessee in the
PandL A/c for doubtful debts and diminution in value of re-possessed stock by
disregarding the provisions of Section 43D and 36(1)(viia) of the Act?
.
2. Whether the policy directions issued by RBI to finance companies under
the provisions of Reserve Bank of India Act, 1934 would have an overriding
effect over the provisions of Income Tax Act,1961?
.
3. Whether the Tribunal was justified in law in deleting the disallowance
of Rs.58,86,433/- made by the CIT(A) under Section 14A at the Appellate stage
holding the same to be beyond his jurisdiction?
.
4. Whether in view of Section 14A of the Income Tax Act, ITAT was correct
in law in allowing deduction of expenditure incurred by the assessee in relation
.
.
to dividend income which admittedly does not form part of total income under the
Act?
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5. Whether the Tribunal has correctly interpreted the provisions contained
in Section 14A of the Income Tax Act while deciding the issue and controversy
before it??
.
.
The Appellant is directed to file Paper book within three months, as per
rules.
List with ITA Nos.7/02, 408/03 and 1387/2006 in regular course.
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.
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VIKRAMAJIT SEN, J
.
.
.
S. MURALIDHAR, J
NOVEMBER 28, 2006
dn