Tribunal restricts disallowance under section 14A to Rs. 8 lakhs, dismissing Revenue's appeal.

The Tribunal affirmed the CIT(A)'s decision to restrict the disallowance u/s 14A to Rs. 8 lakhs based on the peculiar facts and circumstances of the case. The Revenue's appeal challenging the restriction was dismissed as the Tribunal found no infirmity in the CIT(A)'s order, despite the Revenue's argument that Rule 8D should apply.

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Issues involved: Appeal against the order of CIT(A) restricting disallowance u/s 14A read with Rule 8D.

Summary:
The Revenue filed an appeal against the CIT(A)'s order restricting the disallowance u/s 14A read with Rule 8D. The assessee declared an income of Rs. 1,69,93,970/- and claimed dividend income of Rs. 4,05,57,128/-. The Assessing Officer (A.O.) required details of expenditure for earning dividend income and made a disallowance of Rs. 47,64,086/-. The CIT(A) restricted the disallowance to Rs. 8 lakhs, considering the expenses debited in the profit and loss account. The Revenue appealed before the Tribunal, arguing that Rule 8D was applicable as per the judgement of the Hon'ble Mumbai High Court. The Tribunal upheld the CIT(A)'s decision, stating that no infirmity was pointed out in the order. The departmental ground was dismissed, and the appeal filed by the Revenue was also dismissed.

In conclusion, the Tribunal affirmed the CIT(A)'s decision to restrict the disallowance u/s 14A to Rs. 8 lakhs based on the peculiar facts and circumstances of the case.

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