2015 (1) TMI 1289

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....lant  : Shri F.V. Irani For the Respondent : Shri Asghar Zain O R D E R PER R.C. SHARMA, A.M. : These are the appeals filed by the assessee against two separate orders of ld. CIT(A) - 4 dated 3-7-2012 and 17-10-2012 for the assessment years 2008-09 and 2009-10 in the matter of order passed u/s 143(3) of the Income Tax Act, 1961. 2. The common grievance in both these appeals rel....

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....egic investment should be excluded for attributing administrative expenses for making disallowance u/s 14A of the Act. The ld. A.R. has placed reliance on the following decisions:- i) HSBC Securities and Capital Markets (I) P. Ltd. - ITA No. 3186/M/08 ii) Zenstar Technologies Ltd. - ITA No. 4538/M/05 iii) Shri Bhalchandra R. Sule - ITA No. 3684/M/05 iv) EIH Asso....

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....ties. 5. We have considered the rival contentions, carefully gone through the orders of authorities below. We have also deliberated upon the judicial pronouncements cited with reference to the exclusion of investment made in the companies which are strategic in nature. As per the judicial pronouncements cited above, such investments should not be taken into account for working out the disallowa....