2014 (4) TMI 1081

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.... For the Respondent: Shri J.P. Jhangid, Sr.D.R. O R D E R PER SHRI KUL BHARAT, JUDICIAL MEMBER: This appeal by the Assessee is directed against the order of the Ld. Commissioner of Income Tax(Appeals)-XIV, Ahmedabad ('CIT(A)' for short) dated 13/08/2012 pertaining to Assessment Year (AY) 2009- 10. The Assessee has raised the following grounds of appeal:-     &nbs....

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.... made disallowance by invoking the provisions of section 14A r.w.r.8D of the IT Rules, 1962 and amounting to Rs. 14,16,572/-. Against this, the assessee filed an appeal before the ld.CIT(A), who after considering the submissions of the assessee partly allowed the appeal, thereby the grounds taken against disallowance u/s.14A was dismissed. 3. The assessee is in further appeal before us. The ld.....

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....'000') 113,220, reserve and surplus Rs.(in '000')153,251, whereas secured and unsecured loan is Rs.(in '000')1,468. He submitted that the law is well-settled, if the assessee is having sufficient interest-free funds, the presumption is that the assessee has invested out of own funds. He further submitted that even the addition towards administrative expenses is very high as against the dividend in....

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....ken for the purpose of disallowance in respect of the administrative expenses. He submitted that the AO as well as the ld.CIT(A) has taken ½% of the entire investment, which is ex-facie illegal and unjustified. 5. We have heard the rival submissions, perused the material available on record and gone through the orders of the authorities below. We find force in the contention of the ld....