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2015 (4) TMI 1050
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.... This is an appeal filed by the assessee against the order of CIT(A) dated 23-11-2011, for the A.Y.2007-08 in the matter of order passed u/s.250(6) of the I.T.Act, wherein following grounds have been taken by the assessee :- The appellant objects to the order dated November 23, 2011 passed by the learned Commissioner of Income tax -2, Mumbai on the following among other grounds: Payment to r....
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....lant prays for relief as per the grounds of appeal. 6. Each one of the above grounds of appeal is without prejudice to the other. 7.The appellant reserves the right to amend, alter or add to the grounds of appeal." 2. At the outset, it was submitted by ld. AR that ground No.1 with regard to disallowance of payment made to partner amounting to Rs. 1,63,26,270/- has already be....
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....1,74,591/-. It was submitted by ld. AR that no satisfaction was recorded by the AO before invoking Section 14A. Furthermore, it was contended that the relevant assessment year under consideration is 2007-08, wherein Rule 8D is not applicable as per the decision of the jurisdictional High Court in the case of Godrej & Boyce Mfg. Co. Ltd., 328 ITR 81. 6. We have considered rival content....
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....ter of record that rule 8D Is not applicable for the relevant assessment year 2007-08 under consideration, however, reasonable disallowance is warranted as per verdict of Hon'ble High Court in case of Godrej & Boyce Mfg. Co. (supra). In the interest of justice and fairplay, we restore this issue back to the file of AO for deciding afresh after considering assessee's contention regarding interest f....