JUDGMENT

Akil Kureshi, J. - This Appeal is filed by the revenue to challenge a judgment of Income Tax Appellate Tribunal. Following questions were presented for our consideration;

(a) Whether, on the facts and in the circumstance of the case and in law, the Hon''ble Tribunal erred in comparing the overall average rate of interest of 11.30% during the year without appreciating that Nesarikar each series of debentures issued in different years was a separate international transaction and each transaction was required to be benchmarked separately?

(b) Whether, on the facts and in the circumstance of the case and in law, the Hon''ble Tribunal erred in not appreciating the fact that the amount of disallowance under section 14A of the Act has to be computed as per Rule 8D of the I.T. Rules, 1962 as held in the order of the Hon''ble High Court in the case of M/s Godrej & Boyee Manufacturing Co. Ltd.?

(c) Whether, on the facts and in the circumstance of the case and in law, the Hon''ble Tribunal erred in deleting the addition on account of interest accrued from (1) Brandhouse Retails Ltd. (2) Sanghi Inds Ltd. and (3) Ganesh Benzoplast Ltd. holding that these three parties had become NPA?

2.