This appeal filed by Madan Mohan Lall Shriram (P) Ltd. raises three objections against order of CIT (A). appeal relates to asst. yr. 1971-72, previous year of which ended on 30th June, 1970. assessee, private limited company, has income from business, dividends, rent and also managing agency remuneration from limited company called Bengal Potteries. first objection in this appeal relates to determination of relief under s. 80M of IT Act, 1961 ('the Act'). income by way of dividend was Rs. 26,27,907. assessee claimed relief under s. 80M on this entire amount but ITO deducted from this dividend sum by way of interest of Rs. 5,99,340, said to have been paid on money borrowed for investment in shares and allowing 60 per cent on balance, allowed relief of Rs. 12,15,244. question, thus, was whether relief should be allowed with reference to gross dividend received by assessee or after deducting expenses by way of interest as above. According to assessee's calculation, interest attributable to dividend is only Rs. 11,042, whereas according to calculation adopted by ITO, interest attributable to this dividend was Rs. 5,99,340. When ITO completed assessment originally deducting interest of Rs. 5,99,340 as against Rs. 11,042 claimed, rejecting claim of assessee that to compute deduction due under s. 80M, it should not be gross dividend income but net dividend income. Thereupon, there was appeal to AAC, who agreed with assessee's contention that it was gross dividend that should be taken into consideration under s. 80M and not net dividend. But he did not touch upon question as to whether interest should be Rs. 5,99,340 or Rs. 11,042. Revenue appealed to Tribunal. In that appeal, Tribunal held that finding of AAC that it should be gross dividend that should be considered for s. 80M, was not correct and on alternative ground of finding out amount of interest allocable to dividend, matter was set aside and sent back to AAC with following observations: " In view of this finding, it would become necessary to ascertain as to what part of interest income has to be deducted from dividend income under s. 57. As this controversy has not been touched upon by Appellate Asstt. CIT, it is necessary to restore case back to him for disposing of appeal de novo with regard to this point after hearing both sides." Pursuant to this direction, matter was again heard by CIT (A). This time, before CIT (A), assessee raised two contentions, which according to it were closely connected with issue of allowance of interest and also determination of quantum of relief that could be given under s. 80M, one was that assessee's main source of income is to acquire shares to gain control of managed companies and also to act as managing agents. sources of income of assessee are such that funds got so mixed up that it is not possible to link or trace amount of investment made in each line of business and to trace investment to any particular borrowal or own capital. entire business is integrated whole and, therefore, interest payable by assessee cannot be segregated as to income from dividend or income from other business activities. entire interest paid should, therefore, be allocated under head 'Profits and gains of business or profession' and nothing should be allocated towards dividend. In support of this contention, reliance was placed upon decision of Supreme Court in CIT vs. Indian Bank Ltd. (1965) 56 ITR 77 (SC) and few High Courts decisions, which it is not necessary for us to refer to at this stage. point that was made, to put it shortly, was, where assessee has more than one source of income, all of which are inter-dependent, inseparably linked up and indivisible, expenses incurred by assessee should not be artificially allocated and entire expenses must be taken as expenditure for purposes of business activity. Another point raised was that while assessee-company paid interest, it also received interest and if at all it is decided to allocate interest to dividend income and other business income, only net interest paid must be allocated and not gross interest as was done in this case. Both these points were taken up in cross-objections filed before Tribunal, when it disposed of original appeal. CIT (A) did not permit assessee to raise these two new grounds with following observations: " I am of view that within my invested jurisdiction in this appeal, I shall not be able to go beyond directions of Tribunal. clear mandate is to enter into enquiry as to facts, which may justify allocation of part of enter into enquiry as to facts, which may justify allocation of part of interest expenses; assessee on its part having already accepted that allocable part was only Rs. 11,042. In view of above, I reject new points raised by learned A.R. and proceed to examine facts in context of enquiry for allocation of interest towards earning of dividend income under s. 57. " Then he proceeded to consider amount to be allowed by way of interest under s. 57 of Act and found that for earlier assessment years, AAC had evolved formula and that formula holds good for this year also. That formula was to allocate interest on basis of investment made in shares of joint stock companies with reference to total assets. By applying that formula, he found that interest of Rs. 5,99,340 allocated by ITO was correct and upheld it. Now in this appeal filed against that order, points raised by learned counsel for assessee, O.P. Vaish, was that interpretation placed by CIT (A) on order of Tribunal was incorrect. Tribunal set aside assessment not for purpose of finding out whether interest allowable should be Rs. 11,042 or Rs. 5,99,340, but to ascertain whether any interest at all was allocable under s. 57 on peculiar facts of this case. direction of Tribunal was to go into matter de novo and not to restrict it to limited scope of finding out allocable expenditure. When Tribunal was mentioning that it was necessary to ascertain what part of interest income was to be deducted from dividend under s. 57, it did not mean that it was confined to either Rs. 11,042 or Rs. 5,99,340 but also to fact whether any interest at all needs to be deducted. That was reason why Tribunal felt that matter must be disposed of by AAC from starting point. use of expression that AAC is to dispose of appeal de novo with regard to this point, gives ample scope to CIT (A) to decide this issue from all angles enlarging it to point whether interest at all requires to be allocated or not. If on examination of accounts, it is found that even calculations made by assessee were incorrect or calculations made by assessee were correct, it could not be interpreted that Tribunal desired that those incorrect calculations should be ignored and allowance should be confined either to Rs. 11,042 or Rs. 5,99,340. This kind of interpretation on order of Tribunal as limiting scope of enquiry of CIT (A) is unwarranted and that he should have gone into this question from all its angles and then arrived at finding whether any part of interest has to be deducted from dividend income under s. 57. That was broad principle. learned Departmental Representative, on other hand kly relying on order of CIT (A), submitted that assessee was trying to enlarge scope of enquiry at level of CIT (A) and it should not be permitted. Accepting assessee's contention would, according to learned Departmental Representative, mean rewriting direction of Tribunal given earlier. He also submitted that it was never case of assessee that interest should be deducted in its entirety against business income and nothing should be deducted against dividend income. If that were so, question of arriving at figure of Rs. 11,042 as allocable interest towards dividend, would not arise. There is, thus, contradiction in assessee's stand and CIT (A) was, therefore, right in not permitting assessee to change its stand and make it mutually contradictable. In our opinion, view taken by CIT (A) does seem on narrower side. directions given by Tribunal quoted above, in our opinion, do vest in AAC with power to enquire into matter in all its aspects and not to restrict in any manner than to arrive at interest allowable under s. 57 against dividend income. It is difficult to read directions given by Tribunal, confining it to allowing of either Rs. 11,042, as claimed by assessee, or Rs. 5,99,340, as claimed by Revenue. There is nothing in directions given by Tribunal limiting jurisdiction of CIT (A) to go into this question. As rightly pointed out on behalf of assessee, if on verification, it is found that there are mistakes either in calculation of assessee or Department, it is certainly open to CIT (A) as appellate authority to rectify those mistakes and arrive at correct figure. Once assessment is set aside and matter is restored to file of CIT (A), his powers to go into that matter become co-extensive with powers he had while disposing of original appeal. There is no difference between powers of CIT (A) in disposing of appeal originally or in disposing of appeal, which was set aside and restored to his file provided there are no directions limiting scope of enquiry. When appeal is restored to his file, it becomes appeal on his file and in deciding that appeal, he may exercise such powers as are open to him to determine issue de novo and his powers in this regard are as plenary as co-terminous as with that of ITO. CIT (A) can do what ITO could do. He can also direct ITO to do what latter had failed to do CIT vs. Kanpur Coal Syndicate (1964) 53 ITR 225 (SC). There is another aspect of matter. appeal is merely continuation of original proceedings and unless some fetters are placed upon powers of appellate authority by express words, he can exercise same powers, as are exerciseable by ITO. relevance of this observation would become at once clear when we refer to what happened before ITO insofar as this claim is concerned. We find from paper-book that on 23rd Jan., 1972, assessee wrote to ITO in connection with assessments for asst. yrs. 1966-67 and 1967-68 and later on 23rd Feb., 1973, in connection with asst. yr. 1970-71 and much later on 22nd March, 1974, in connection with present assessment year, pointing out to ITO genesis of investment made by assessee-company in shares. In elaborate statement prepared and filed before ITO, assessee-company had shown name of company of which shares are purchased, quantity of shares purchased, amount invested, date of investment and how amount came, whether by overdraft from bank or whether out of balance already available in bank, and interest, if at all, paid on those purchases. cursory glance of this statement would show to any one that in majority of cases, these shares were purchased out of existing money and no borrowed funds were utilised. If any one had looked into this statement and applied his mind, verified them with regard to books, conclusion will have been reached that assessee purchased these shares out of its own money and not out of borrowed funds and where overdraft money was utilised, interest payable thereon was very nominal. Such interest calculations were arrived at Rs. 64,242, Rs. 12,765 and Rs. 17,477 for years ending on 30th June, 1965, 30th June, 1966 and 30th June, 1969, respectively. Prepared in same way, interest payable for year under appeal came to Rs. 11,042. When ITO by applying s. 57 has to arrive at interest payable on investment made in purchase of shares to determine dividend income, this exercise has to be gone through. We doubt whether it is open to ITO to ignore this exercise in toto and to arrive at interest on basis of gross interest paid by company with reference to total assets acquired and investment made in shares. We are not expressing any definite opinion on correctness of formula arrived at by AAC in earlier years and which was accepted by CIT (A) this year but what we are trying to highlight at this juncture is fact that assessee has made attempt to show that at time these shares were purchased, no borrowed funds were involved. Consequently, no interest of such magnitude as ITO had attributed, was also involved. Should or should not this matter be enquired into? Did Tribunal mean that this matter should not be enquired into at all when it set aside assessment, restored appeal to file of AAC for finding out that part of interest attributable to dividend income within meaning of s. 57? assessee now contends that first of all no borrowed money was utilised in purchasing of shares in such large quantity. Secondly, even purchase of shares having regard to nature of business conducted is business necessity, i.e., activity. Unless these points are discussed, how can it be said that interest of particular amount is to be deducted in arriving at dividend income for purposes of s. 57. Further, when interest is to be taken into consideration and when there is also interest received by assessee on amounts it advanced out of its mixed funds, should that interest be not deducted from gross interest payable to arrive at net interest for purposes of allocation under s. 57? Does s. 57 speak of only gross interest? Does it not speak of net interest or these questions are not germane to issue of allowance of interest under s. 57 to determine income from dividend? These are aspects which Tribunal wanted AAC to go into and not to look at problem with blinkers. We are, therefore, of opinion that CIT (A) is not justified in construing directions given by Tribunal as putting fetter on his power of enquiry and that his enquiry is confined only to whether Rs. 11,042 is to be allowed or Rs. 5,99,340 should be allowed. We also find that CIT (A) has not discussed as to how assessee's claim of Rs. 11,042 should be rejected and why claim of CIT (A) should be approved of. demerits, if any, in assessee's case were not at all pointed out. This is also lacuna in order passed by CIT (A). Having regard to these aspects, we think it would be very proper and just that matter should be restored again to file of CIT (A), with direction that he should go into all these aspects again and then give his decision thereon keeping in view above discussion. He should decide whether at all any interest is allocable as deduction from dividend income having regard to assessee's contention that interest was attributable only to business activities and nothing is allocable towards dividend on ground that its activity was indivisible whole or whether gross interest should be taken or net interest should be taken and also whether claim of assessee that Rs. 11,042 alone should be deducted and not Rs. 5,99,340. Normally, we would not have dealt with this point in so elaborate manner except for impression created on our mind that CIT (A) and Departmental Representative appeared to have genuinely felt that there was fetter placed upon their powers of enquiry when matter was set aside by Tribunal. It is to remove what we consider misapprehension that we discussed matter in somewhat detailed way. next ground relates again to deduction to be allowed under s. 80M but in slightly different way. ground appeared though innocuous, is in following terms: " 5. That, on facts and in circumstances of case and in law, CIT (A) erred in deducting dividend exempt under s. 80K in arriving at dividend on which deduction under s. 80M is available. " perusal of order of CIT (A) would show, how he dealt with this matter: " 10.3 In view of retrospective operation of s. 80AA, which is to be given effect to in this appeal, and in view of Tribunal's observation extracted above, I allow appellant to raise additional ground of appeal. However, I do not agree with construction placed by learned A.R. on provisions of ss. 80AA, 80M and 80K. We may discover mischief aimed at by amendment introduced by Finance (No. 2) Act, 1980. As observed by Supreme Court in Sole Trustee, Loka Shikshana Trust vs. CIT 1975 CTR (SC) 281: (1982) 101 ITR 234 (SC), real meaning and purpose of words used may be understood satisfactorily with reference to past history of legislation on subject and speech of mover in Parliament. memorandum explaining provisions of Bill states that in order to get over difficulty caused by ruling of Supreme Court in case of Cloth Traders (P) Ltd. vs. Addl. CIT (1979) 10 CTR (SC) 393: (1979) 118 ITR 243 (SC) and there always being intention to grant deduction at specified percentage on net amount, s. 80AA was introduced. Therefore, there was no intention to render s. 80M(2) redundant. Even on plain reading what s. 80AA clarified, is that income by way of dividends, which is basis of deduction under s. 80M(1), shall be computed in accordance with relevant ss. 56 to 59. Sub-s. (2) ibid. which is to avoid deduction in respect of same income being allowed 100 per cent under s. 80K and 60 per cent under s. 80M(1) comes into play after 'the income by way of dividends' has been determined under s. 80M(1), r/w s. 80AA. words in parenthesis in s. 80AA should apply to first stage of determining income by way of dividends and not to later stage, when 60 per cent of income is to be determined. So understood, there should remain no doubt as to real meaning and purpose of s. 80AA or s. 80M(2). I, therefore, reject additional ground of appeal. " question that is now debated before us proceeded on same lines as before authorities below. Sec. 80M(1) and (2) is in following terms: " (1) Where gross total income of assessee, being domestic company, includes any income by way of dividends from domestic company, there shall, in accordance with and subject to provisions of this section, be allowed, in computing total income of assessee, deduction from such income by way of dividends of amount equal to (a) in respect of such income by way of dividends from company formed and registered under Companies Act, 1956 (1 of 1956), after 28th Feb., 1975, and engaged exclusively or almost exclusively in manufacture or production of any one or more of articles or things specified in items 2 and 3, item 4 (excluding alloy, malleable and S.G. iron castings), items 7 to 15 (both inclusive), items 17 and 18, item 23 (excluding refractories) and items 24, 26, 27 and 29 in list in Ninth Schedule. whole of such income; (b) in respect of such income by way of dividends other than dividends referred to in clause (a) sixty per cent of such income. (2) Where company to which this section applies is entitled also to deduction under s. 80K, deduction under sub-s. (1) shall be allowed in respect of income by way of dividends referred to therein as reduced by amount of deduction under s. 80K. " We are concerned more in this appeal with effect of sub-s. (2) of s. 80M, r/w s. 80K of Act, and another section having bearing on this, s. 80AA o f Act, which was inserted by Finance (No. 2) Act, 1980, with retrospective effect from 1st April, 1968. To appreciate controversy before us, s. 80AA also needs to be reproduced which is as under: " Where any deduction is required to be allowed under s. 80M in respect of any income by way of dividends from domestic company which is included in gross total income of assessee, then, notwithstanding anything contained i n that section, deduction under that section shall be computed with reference to income by way of such dividends as computed in accordance with provisions of this Act (before making any deduction under this Chapter) and not with reference to gross amount of such dividends. " Note: This topic was originally dealt with by s. 85A which was inserted by Finance Act, 1965, w.e.f. 1st April, 1965. Sec. 80M was inserted in place of s. 85A which was deleted, by Finance (No. 2) Act, 1967, w.e.f. 1st April, 1968. For entitlement of relief under s. 80M, condition is that gross total income of assessee, which should be domestic company, should include income by way of dividend if dividend happened to be from companies categorised in cl. (a), whole of such dividend would be deducted but if dividend happens to be falling in category (b), only 60 per cent thereof is to be exempted. In this case, it is 60 per cent category that is thereof is to be exempted. In this case, it is 60 per cent category that is disputed. Sub-s. (2) of s. 80M puts embargo on allowance of deduction under s. 80M(1). It will be seen from section quoted above that if assessee happens to be company entitled to relief both under ss. 80M and 80K, deduction under s. 80M would be as reduced by deduction allowable under s. 80K. In other words, in case of company entitled to relief under ss. 80M and 80K, deduction under s. 80K is given preference over deduction under s. 80M. Here in case before us, relief due to assessee under s. 80K is of order of about Rs. 18.91 lakhs. What assessee claimed was, that of gross dividends of Rs. 26,27,907 no interest was allocable as deduction and from gross amount deduction allowable under ss. 80K and 80L of Act was only Rs. 3,160 and of balance of Rs. 26,24,747 deduction under s. 80M at 60 per cent should be allowed, which worked out to Rs. 15,74,848. What ITO did was, he deducted interest of Rs. 5,99,340 from dividend and also 80K and 80L deduction of Rs. 3,160 and arrived at balance of Rs. 20,25,407, whereof he allowed 60 per cent which came to Rs. 12,15,244. As per order of CIT (A), ITO rectified order and in that rectified order after deducting interest allocable of Rs. 5,99,340 from gross dividend of Rs. 26,27,987, he further deducted Rs. 18.91 lakhs as deduction under s. 80K and arrived at balance of only Rs. 1,33,369 for purpose of allowing deduction under s. 80M. assessee now claims that deduction of Rs. 18,91,198 under s. 80K should not have been allowed. This it says is meaning of and supported by provisions of s. 80AA. Now s. 80AA, as extracted above, would show how deduction under s. 80M is to be computed. It says where any deduction is required to be allowed under s. 80M, notwithstanding anything contained in that section, deduction under that section shall be computed with reference to income by way of such dividend as computed in accordance with provisions of this Act before making any deduction under this Chapter and not with reference to gross amount of such dividend. What Mr. Vaish argues is even though s. 80M(2) provided that deduction under s. 80K must be allowed first, before giving deduction under s. 80M(l), s. 80AA contemplated computation of relief due under s. 80M and it specifically provided that deductions spoken of in this Chapter, i.e., Chapter VIA of Act, should not be considered while other provisions of Act could be applied. Mr. Vaish's emphasis was that when s. 80AA provided that amount of deduction to be given under s. 80M is to be computed before making any deduction under this Chapter, meaning Chapter VIA, it meant in effect that deductions spoken of in s. 80K, which is part of Chapter VIA, is to be ignored. In other words, enactment of s. 80AA is to nullify effect of s. 80M(2). If that is object, ITO was not justified in deducting Rs. 18.91 lakhs from net dividend after deducting interest allocable to it. Departmental Representative says that this is not object of section. whole object of s. 80AA was to supersede decision of Supreme Court in case of Cloth Traders (P) Ltd. vs. Addl. CIT (1979) 10 CTR (SC) 393: (1979) 118 ITR 243 (SC), where Supreme Court held that deduction under s. 80M in respect of inter-corporate dividend is to be computed with reference to gross amount of such dividend and not net amount arrived at minus admissible expenditure. That was reason why s. 80AA was inserted with retrospective effect from 1st April, 1968, providing that deduction under s. 80M is to be computed with reference to net dividend income and not gross dividend income. If this is entire object of enacting of s. 80AA then it cannot be said that its object was to nullify effect of s. 80M( 2), which was inserted w.e.f. 1st April, 1972. One has no relation to other. He then gave us instances to show where both could co-exist in furtherance of legislative intention. Vaish, on other hand, by citing several examples opposed this view. But we are of view that view canvassed on behalf of assessee i s difficult to accept. Assuming for minute that Vaish is right, what s. 80AA clearly says is: (i) where any deduction is required to be allowed under s. 80M in respect of any income by way of dividend, (ii) notwithstanding anything contained in s. 80M, (iii) deduction under s. 80M shall be computed with reference to, (iv) income by way of such dividend as computed in accordance with provisions of this Act, (v) 'before making any deduction' under this Chapter and (vi) not with reference to gross amount of such dividend. words in parenthesis 'before making any deduction under this Chapter' would no doubt refer to deductions allowable under Chapter VIA, which have bearing upon determination of income under s. 80M and that is deduction spoken of in s. 80K. purpose of s. 80AA is to determine and arrive at quantum of deduction to be allowed under s. 80M. controversy before s. 80AA inserted was, what should be quantum of income. Supreme Court said that it is gross and not net. legislature intended it to be otherwise. It, therefore, said that quantum of deduction that is to be given for purpose of s. 80M is only net amount. It, therefore, provided that in arriving at quantum of deduction under s. 80M from gross dividend, deduct expenditure allocable to it in accordance with provisions of Act but not with reference to gross amount of such dividend. Once that quantum of deduction is arrived at as stipulated in s. 80AA, then one has again to go to s. 80M for purpose of granting deduction. Even after amount of relief due under s. 80M is arrived at as per s. 80AA, that amount does not automatically become entitled to relief. It is again to be processed as provided for in s. 80M(2). That is why section says that deductions to be allowed shall be computed with reference to income by way of dividend as computed in accordance with provisions of this Act but not with reference to gross amount of such dividend, taking care to see that gross amount of dividend is not further diminished by deductions to be made under s. 80M(2). If we trace history of s. 80M, it would become clear that present sub-s. (2) of s. 80M, inserted w.e.f. 1st April, 1971, appeared even earlier as Expln. 2 to s. 80M, when it provided: " Where company to which this section applies is entitled also to deduction in respect of income by way of dividends under s. 80K or s. 80L, deduction under sub-s. (1) shall be allowed in respect of income by way of dividends referred to therein as reduced by aggregate of deductions, if any, in respect of income by way of dividends under s. 80K and s. 80L. " This Explanation later became sub-s. (2) of s. 80M inserted by Finance (No. 2) Act, 1971, w.e.f. 1st April, 1972. whole idea is that if assessee is entitled to relief under ss. 80K and 80M, relief under s. 80K must first be given and only balance shall be entitled to relief under s. 80M. While s. 80M gives relief in respect of inter-corporate dividends received by domestic companies, s. 80K relief is allowable to shareholders. Since shareholder can also be domestic company receiving dividend from another company, object perhaps is to see that no double advantage is taken by same object perhaps is to see that no double advantage is taken by same assessee. history of s. 80M, particularly reason for inserting s. 80M(2), must be borne in mind to understand purpose of insertion of s. 80AA, which as we have noticed earlier is to off set effect of decision of Supreme Court in case of Cloth Traders (P) Ltd. (supra) Now coming back to s. 80AA, its sole purpose is to determine quantum of deduction available for s. 80M. It must be understood as section laying down procedure for arriving at quantum of deduction. It says to repeat from gross dividend income, deduct expenses allowable under provisions of Act but not any deduction under Chapter VIA, that is not to say that effect of s. 80M(2) is nullified. After arriving at quantum as provided for in s. 80AA, from that quantum of income, further deduction allowable under s. 80K is to be deducted as provided for in sub-s. (2) of s. 80M. It is also very significant to note that when s. 80AA spoke of deduction allowable under s. 80M, deduction allowable under s. 80M is specified in s. 80M(1) and 80M(2) does not speak of deduction in context of arriving at it but only places procedural restriction as to which relief should take precedence. That is why s. 80M(2) also refers to deduction allowable under s. 80M as 'deduction under sub-s. (1)'. It is, therefore, difficult to understand that legislature by insertion of s. 80AA has totally annihilated effect of sub-s. (2) of s. 80M. effect of that section still remains and only thing is that it comes into operation after deductions allowable under s. 80M(1) is computed as provided for in s. 80AA. Thus, in context of s. 80M(1), s. 80AA must be read as proviso to s. 80M(1) and not in substitution of s. 80M(2). Taking case of assessee, for example, gross dividends are Rs. 26,27,987. Assuming that assessee's contention that no interest is allocable towards gross dividend is right, then from amount of gross dividend, deduction allowable under s. 80K, which was shown in computation sheet at Rs. 18,91,198, must be deducted and on balance of Rs. 7,36,709, 60 per cent relief ought to be given. In this process, assessee is getting relief of Rs. 18,91,198 under s. 80K and also 60 per cent of Rs. 7,36,709 under s. 80M. He is not denied any relief, and that assessee is getting both reliefs contemplated. This seems to be intention of legislature. If this is so, we cannot subscribe to contention put forward on behalf of assessee that for purpose of granting relief under s. 80M, deduction under s. 80K of Rs. 18,91,198 should be totally ignored. If we understood contention of assessee correctly, then accepting interpretation placed by assessee upon interpretation of these ss. 80AA and 80M, would mean that assessee would get relief under s. 80K of Rs. 18,91,198 and again full relief of Rs. 26,27,908, which does not seem to us to be legislature's intention. If intention of Parliament is to nullify effect of s. 80M(2), it would have done so in very explicit terms. We, therefore, hold that this view canvassed on behalf of assessee is not borne out by language of s. 80M(2), r/w s. 80AA. view taken by CIT (A) appealed to us to be correct and we endorse it. (This para is not reproduced here as it involves minor issue.) In result, appeal is allowed in part. *** MADAN MOHAN LALL SHRIRAM (P) LTD. v. INSPECTING ASSISTANT COMMISSIONER