2014 (9) TMI 996

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....her the ld. CIT(A) was justified in deleting the addition u/s 14A r.w. Rule 8D even when the A.O. had made a proximate cause for disallowance of Rs. 13,58,751/- under section 14A of the I.T. Act. 2. On the facts and in the circumstances of the case and in law, whether the ld. CIT(A) was justified in relying on his own order of the earlier year thereby ignoring the fact that the A.O. had differentiated the facts of the present case from that of the earlier year. 3. The appellant prays that the order of CIT (Appeals) on the above ground be set aside and that of the Assessing Officer restored." 3. Rival contentions have been heard and perused the records. Facts in brief are that the assessee is a film artist by profession.....

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....ofit and Loss Account of the appellant shows that the appellant has not made any claim of expenditure incurred in relation to exempt income, therefore, the provisions of section 14 A (1) r.w.s. 14A(2) of the Act are not attracted. The AO has also not given any findings on whether the assessee has made a claim of expenditure in relation to exempt income and the claim is not correct. It is seen that the assessee has earned dividend of Rs. 10,245/- which has been directly credited to bank through ECS. The interest of Rs. 69,90l/- received on PPF, for which a journal entry is passed on 31-3-09 and similarly, interest of Rs. 66,02,652/- on tax free Bonds is credited by journal entries passed on 3 1-3-09. Thus, no expenditure has been earned for ....