2014 (5) TMI 768

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....restricted by the CIT(A) by the impugned order to Rs.1,00,000. Grounds of the Revenue in that behalf read as follows- "1. The order of the CIT(A) is erroneous on facts and in law. 2. The CIT(A) ought to have appreciated that the disallowance of expenditure u/s. 14A r.w.r. 8D is correctly worked out at Rs.10,69,818. 3. The CIT(A) ought not to have estimated the disallowance of expenditure u/s. 14A at Rs.1,00,000 without any cogent reasons. 4. ...." 3. Facts in brief are that the assessee is a cooperative bank with limited liability engaged in banking business. The Assessing Officer while making the assessment noted that the assessee has certain interest bearing loans from various related (share holders) persons and interest is paid on t....

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.... warranted. However, finding the estimated disallowance made by the Assessing Officer to be on the higher side, the CIT(A) restricted the same to Rs.1 lakh, deleting the balance addition made by the Assessing Officer. 5 Aggrieved by the relief granted by the CIT(A), Revenue preferred the present appeal before us. 6. We heard both sides and perused the orders of the Revenue authorities and also perused the written submissions filed by the learned counsel for the assessee before us. We find that in the context of the disallowance sustained by the CIT(A) out of the total disallowance made by the Assessing Officer in terms of S.14 read with Rule 8D for the assessment year 2010-11 itself, in the context of assessee's appeal ITA No.1411/Hyd/201....