2017 (2) TMI 1254

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....t : Tarandeep Singh, CA ORDER Prashant Maharishi (Accountant Member) 01. This appeal is preferred by revenue against the order of the Commissioner of income tax (appeals) - XVII-B, New Delhi dated 30/04/2014. 02. The revenue has raised in all 3 effective grounds of appeal as under:- 1. on the facts and circumstances of the case and in law, the Ld. CIT (A) has added in deleting....

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....the act through section 14 A read with rule 8D as per which all the clauses (i), (ii) and (iii) of subsection to are duly applicable even if such direct expenses have been added back by the assessee on its own. 03. Briefly stated assessee is a company engaged in the business of investment/dealing in shares and securities and financing activities, who filed its return of income on 23/09/2011 dec....

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....ee and therefore he computed the disallowance as per rule 8D (2) (iii) of Rs. 4 055 1458/- being 0.5% of the average value of investment. Out of this the assessee has already disallowed Rs. 2 127 3863/- and therefore he made and balance disallowance of Rs. 1 927 7595/-. Assessee aggrieved with the order of the Ld. AO preferred appeal before the Ld. CIT (A) who in turn deleted the disallowance of R....

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.... no error in the order of the loaded CIT appeal. He further submitted that even otherwise the disallowance under rule 8D cannot exceed the amount of exempt income. He further stated that all expenditure incurred by the assessee has been disallowed of Rs. 2.13 crores and therefore there is no other expenditure incurred by the assessee. 07. We have carefully considered the rival contentions and a....