2014 (5) TMI 697

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....er Sanjay Arora, A. M.: This is an Appeal by the Assessee directed against the Order by the Commissioner of Income Tax (Appeals)-20, Mumbai ('CIT(A)' for short) dated 20.07.2012, dismissing the assessee's appeal contesting its assessment u/s.143(3) of the Income Tax Act, 1961 ('the Act' hereinafter) for the assessment year (A.Y.) 2009-10 vide order dated 21.12.2011. 2. Opening the arguments ....

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....ed by the Revenue, includes investment in Bank FDRs and a partnership firm, i.e., to the tune of Rs.150 lacs and Rs.50 lacs respectively. Excluding the same would leave a marginal investment in the range of Rs.1.50 lacs, only qua which r. 8D could apply. The assessee has, in fact, earned a nominal dividend at Rs. 14,896/- for the current year. The ld. Departmental Representative (DR), on the ot....

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....follow; the assessee in the instant case claiming interest in the sum of Rs.199.15 lacs (refer, inter alia, Godrej & Boyce Mfg. Co. Ltd. v. Dy. CIT [2010] 328 ITR 81 (Bom) and Cheminvest Ltd. v. ITO [2009] 121 ITD 318 (Del-SB)). Further, it is not only the investment in shares, yielding dividend, but also that in the partnership firm that would stand to be reckoned for the purpose of the relevant ....