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RAVINDER DUDEJA, J.

1. The instant appeal, at the instance of the Revenue, impugns order dated 28.05.2018 passed by the Income Tax Appellate Tribunal ["ITAT"], whereby, the ITAT ruled in favour of the respondent/Assessee and dismissed the appeal preferred against the order passed by Commissioner of Income Tax (Appeals) ["CITA"]. The appeal has been admitted on the following substantial questions of law:-

"A. Did the Income Tax Appellate Tribunal ["ITAT"] fall into error in holding that the entity assessed was no longer in existence having regard to the circumstance that M/s. Infovision Information Services Pvt. Ltd. merely underwent a name change and had responded to the Revenue's notices, having regard to Section 292B of the Income Tax Act, 1961 ["Act"]?

These four appeals filed by two separate assessees have arisen from separate appellate orders passed by learned Commissioners of Income-tax (Appeals), Ahmedabad for the assessment years, 2010-11 & 2011-12.

2. Since facts and issues involved in all these four appeals are similar which is agreed to by both the rival parties before us and that these four appeals were heard together, we deem it appropriate to dispose of all these appeals by this consolidated order for the sake of brevity and convenience. We will first take up the appeal of the assessee in ITA No. 2498/Ahd/2013 for A.Y. 2010-11, and our decision in this appeal shall apply mutatis mutandis to remaining three appeals.

These four appeals filed by two separate assessees have arisen from separate appellate orders passed by learned Commissioners of Income-tax (Appeals), Ahmedabad for the assessment years, 2010-11 & 2011-12.

2. Since facts and issues involved in all these four appeals are similar which is agreed to by both the rival parties before us and that these four appeals were heard together, we deem it appropriate to dispose of all these appeals by this consolidated order for the sake of brevity and convenience. We will first take up the appeal of the assessee in ITA No. 2498/Ahd/2013 for A.Y. 2010-11, and our decision in this appeal shall apply mutatis mutandis to remaining three appeals.

These four appeals filed by two separate assessees have arisen from separate appellate orders passed by learned Commissioners of Income-tax (Appeals), Ahmedabad for the assessment years, 2010-11 & 2011-12.

2. Since facts and issues involved in all these four appeals are similar which is agreed to by both the rival parties before us and that these four appeals were heard together, we deem it appropriate to dispose of all these appeals by this consolidated order for the sake of brevity and convenience. We will first take up the appeal of the assessee in ITA No. 2498/Ahd/2013 for A.Y. 2010-11, and our decision in this appeal shall apply mutatis mutandis to remaining three appeals.

These four appeals filed by two separate assessees have arisen from separate appellate orders passed by learned Commissioners of Income-tax (Appeals), Ahmedabad for the assessment years, 2010-11 & 2011-12.

2. Since facts and issues involved in all these four appeals are similar which is agreed to by both the rival parties before us and that these four appeals were heard together, we deem it appropriate to dispose of all these appeals by this consolidated order for the sake of brevity and convenience. We will first take up the appeal of the assessee in ITA No. 2498/Ahd/2013 for A.Y. 2010-11, and our decision in this appeal shall apply mutatis mutandis to remaining three appeals.

These cross appeals are filed by the Revenue and Assessee against order dated 12.03.2020 passed by the CIT(A)-1, Ahmedabad for the Assessment Year 2012-13.

2. The Revenue has raised the following grounds of appeal :-

ITA Nos.345 & 383/Ahd/2020 Assessment Years: 2012-13 "(1) The ld. CIT(A) has erred in facts and law in deleting the transfer pricing adjustment made in respect of Corporate guarantee fees of Rs.60,83,440/-

(2) The id. CIT(A) has erred in facts and law in deleting the interest disallowance of Rs.1,64,86,560/- u/s.36(1)(iii) of the Act.

These cross appeals are filed by the Revenue and Assessee against order dated 12.03.2020 passed by the CIT(A)-1, Ahmedabad for the Assessment Year 2012-13.

2. The Revenue has raised the following grounds of appeal :-

ITA Nos.345 & 383/Ahd/2020 Assessment Years: 2012-13 "(1) The ld. CIT(A) has erred in facts and law in deleting the transfer pricing adjustment made in respect of Corporate guarantee fees of Rs.60,83,440/-

(2) The id. CIT(A) has erred in facts and law in deleting the interest disallowance of Rs.1,64,86,560/- u/s.36(1)(iii) of the Act.

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आ.(खो और ज).सं./IT(SS)A Nos.103 -108/RJT/20 17 ( नधारण वष /Assessment Years: (2007-08 to 20 12 -13) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. Flat No.201, Block No.37, Race Estate", 2nd Floor, M.G. Road, Course Park, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आ.(खो और ज). सं./IT(SS)A Nos.1 25-130/RJT/20 17 ( नधारणवष / Assessment Years: (2007-08 to 20 12 -13) Karim K. Makhani Assistant Commissioner of Income C/o SADP & Co. Chart ered Vs. Tax, Central Circle-1, 2nd Floor, Accountants, BB House, 5- Amruta Estate, Room No.215, M.G Collegewadi, Near Kathiyawad Road, Rajkot-360001 Gymkhana, R ajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) आयकर अपील सं./ITA Nos.210 -213/RJT/2018 ( नधारण वष /Assessm ent Years: (2 008-09 to 20 09 -10, 2011-12 & 2013-14) Deputy Commissioner of Income Karim K. Makhani Tax, Central Circle-1, "Amruta Vs. 37/301, Race Course Park, Airport Estate", 2nd Floor, M.G. Road, Road, Rajkot Rajkot-360001 थायीले खासं . /जीआइआरसं . /P AN/GIR No.: AMBPM 6370 J (अपीलाथ /Assessee) ( यथ /Respondent) IT(SS)A Nos.103-108/Rjt/2017, 125-130/Rjt/2017 & ITA Nos.210-

These cross appeals are filed by the Assessee and the Revenue as against separate appellate orders both dated I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No 2 Suzlon Engergy Ltd. vs. DCIT 28.02.2023 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as "CIT(A)"), arising out of the separate assessment orders passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Years 2016-17 and 2017-18. Since common issues are involved in both the years namely disallowance u/s.14A rwr 8D and Depreciation on Goodwill, the same are disposed of by this common order for the sake of convenience. Asst. year 2016-17 is taken as the lead case.

These cross appeals are filed by the Assessee and the Revenue as against separate appellate orders both dated I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No 2 Suzlon Engergy Ltd. vs. DCIT 28.02.2023 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as "CIT(A)"), arising out of the separate assessment orders passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Years 2016-17 and 2017-18. Since common issues are involved in both the years namely disallowance u/s.14A rwr 8D and Depreciation on Goodwill, the same are disposed of by this common order for the sake of convenience. Asst. year 2016-17 is taken as the lead case.

These cross appeals are filed by the Assessee and the Revenue as against separate appellate orders both dated I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No 2 Suzlon Engergy Ltd. vs. DCIT 28.02.2023 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as "CIT(A)"), arising out of the separate assessment orders passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Years 2016-17 and 2017-18. Since common issues are involved in both the years namely disallowance u/s.14A rwr 8D and Depreciation on Goodwill, the same are disposed of by this common order for the sake of convenience. Asst. year 2016-17 is taken as the lead case.

and background of the case:

The Appellant filed an RTI application dated 21.09.2023 seeking information on following points:-

"What kind of punishment is sanctioned by the law for any Pilot who gets the RTR permit or licence on the basis of false documents?"

The CPIO, Sr. DWA (COP & regulations) vide letter dated 05.10.2023 replied as under:-

"- Information sought does not fall under purview of RTI Act 2005, hence this RTI is closed"

Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 08.10.2023. The FAA vide order dated 08.11.2023 stated as under:-

"Reply :- I have gone through the case and found that information sought was denied by the CPIO stating that the information did not fall under the purview of the RTI Act, 2005. The undersigned is convinced with the above reply in view of Section 8-1(j) of the RTI Act. 2005."

and background of the case:

The Appellant filed an RTI application dated 21.09.2023 seeking information on following points:-

"To, Shri Umang Srivastva Sr.DWA (COP) I had complained on 05/05/2023 against Rahul Sinha regarding his COP permit. What action or inquiry has been conducted in this regard?"

The CPIO, Sr DWA (COP & Regulation) vide letter dated 05.10.2023 replied as under:-

"Information sought does not fall under purview of RTI Act 2005, hence this RTI is closed"

Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 08.10.2023. The FAA, JWA vide order dated 08.11.2023 stated as under:-

"Reply :- I have gone through the case and found that information sought was denied by the CPIO stating that the information did not fall under the purview of the RTI Act, 2005. The undersigned is convir.ced with the above reply in view of Section 8-1(j) of the RTI Act. 2005."

Commerzbank analizează opțiunea de a achiziționa o bancă germană de dimensiuni medii ca parte a strategiei de a evita o posibilă preluare de către UniCredit, potrivit Reuters. Planurile sunt într-o etapă incipientă, iar posibilele ținte ar putea include Hamburg Commercial Bank sau Oldenburgische Landesbank. Potrivit surselor Reuters, Commerzbank încearcă să conceapă un plan de apărare, ...

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