The Tribunal after judiciously accepting the contentions of the Assessee, had laid down a principle to apply R. 8D for calculating the disallowance, in consonance with law. This had been accepted by the assessee in earlier years as it had been beneficial to the assessee. The fact that direction resulted in enhancement of disallowance is only consequential and therefore in consonance with the principles laid down. Appeal of assessee is dismissed. (AY. 2010-11)
Punjab State Co-Operative Milk Produce Federation Ltd. v ACIT (2019) 197 TTJ 642/ 174 DTR 155 (Chd.)(Trib.)
S. 254(1) : Appellate Tribunal–Powers-Remand with Directions– Consequential enhancement is held to be valid. [R. 8D]