The assessee was not bound if the acceptance of disallowance is not conceded in the original return of income

Brief fact of the case The assessee company was engaged in the making of High Pressure Gas Cylinder and compressed natural gas cylinders. The assessee has subsidiary company at Dubai. The A.O. disallowed interest as per ruled 8D read with section 14A of the Act w.r.t to dividend income  of Rs.3191330/- which was claimed to be exempted u/s 10(33) and made addition on account of transfer price adjustment related to ‘Guarantee commission’ received by the assessee company on the basis of report of TPO. During F.Y. 2006-07 the Associated Enterprise had taken loan of Rs.86.88 crores i.e, USD 20...