Bangalore560 030 PAN NO : AAACM9840P APPELLANT RESPONDENT IT(TP)A No.1582/Bang/2014 Assessment Year: 201011 M/s. Bosch Limited Deputy Commissioner of Hosur Road Incometax (LTU) Vs. Adugodi Bangalore 560 085 Bangalore560 030 APPELLANT RESPONDENT Appellant by : Shri Sunil Kumar Singh, D.R. Respondent by : Shri Percy Pardiwala, Sr. A.R. Date of Hearing : 09.09.2020 Date of Pronouncement : 16.09.2020 ORDER PER B.R. BASKARAN. ACCOUNTANT MEMBER: These cross appeals are directed against the order dated 28.08.2014 passed by Ld. CIT(A) (Large Tax Payers Unit, Bengaluru) and they relate to the assessment year 201011. IT(TP)A No.1556 & ITA No.1582/Bang/2014 M/s. Bosch Ltd., Bangalore Page 2 of 15 2. The revenue has filed the appeal challenging the decision rendered by Ld. CIT(A) in respective issue relating to disallowance of expenditure on purchase of application software. At the time of hearing, both the parties submitted that the tax effect involved in the appeal filed by the revenue is less than Rs.50 lakhs and hence, in view of the circular no.17/2019 dated 08082019 issued by CBDT, the revenue is precluded from pursuing this appeal. In view of the above, we dismiss the appeal of the revenue in limini. 3. Grounds of appeals urged by the assessee relate to the following issues: a) Disallowance of provision made towards interest payable to Central Excise Department. b) Disallowance of interest expenditure payable to micro, small and medium enterprises. c) Disallowance of part of weighted deduction claimed u/s 35(2AB) of the Act. d) Disallowance made u/s 14A of the Act. e) Disallowance of claim of provisions for bad and doubtful debts. 4. The assessee company is in the business of manufacture of fuel injection equipments, auto electric items, portable electric power tools, etc. The A.O. completed the assessment determining the total income of the assessee at Rs.946.15 Crores by making various additions. The appeal filed by the assessee before Ld. CIT(A) was partly allowed. Aggrieved by the decision rendered by Ld. CIT(A) on the issues cited in the preceding paragraphs, the assessee has filed this appeal before us. 5. The first issue relates to disallowance of claim of interest payable on sales tax, excise duty and customs duty. During the IT(TP)A No.1556 & ITA No.1582/Bang/2014 M/s. Bosch Ltd., Bangalore Page 3 of 15 year under consideration, the assessee claimed a sum of Rs.51,49,959/ as interest payable towards certain demands pertaining to sales tax of Rs.7,59,346/ and customs duty of Rs.43,90,613/. The above said amount was debited to profit & loss account and was not paid. The A.O. proposed to invoke provisions of section 43B of the Actin order to disallow the above said amount. However, the assessee contended that the provisions of section 43B of the Act are not applicable, since "interest on taxes" is not covered u/s 43B of the Act. The A.O. did not accept the contentions of the assessee and accordingly disallowed the above said amount of Rs.51,49,959/, apparently u/s 43B of the Act. The Ld. CIT(A) noticed that an identical issue has been considered by the Bengaluru bench of ITAT in assessee's own case and it was decided against the assessee. Accordingly, the Ld. CIT(A) confirmed the disallowance made by the A.O. 6. We heard the parties on this issue and perused the record. We notice that an identical issue has been considered by the coordinate bench in the assessee's own case in ITA Nos. 713, 714, 7