2017 (12) TMI 811

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....upa Toprani for the respondent ORDER P.C.: One of the contentions raised by the respondent-assessee was that in view of policy circular dated 10th December 2015, this appeal cannot be prosecuted as the disputed claim involved in the appeal is of Rs. 11,80,224/. Our attention is invited to the order dated 12th October 2017 passed by the Apex Court in Civil Appeal No.16815/2017 (Commissione....

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....essing Officer passed an order under which he made disallowance under Section 14A of the Income Tax Act, 1961 (for short "the said Act") read with Rule 8D of the Rules framed under the said Act. An appeal was preferred by the respondent-assessee before the Commissioner (Appeals). The appeal was partly allowed. However, the Commissioner (Appeals) did not interfere with the disallowance under Sectio....

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....Without appreciating the fact that the assessee had huge investments in shares, the incomes from which are exempt from tax and the applicability of Rule 8D in determining the disallowable expenditure, depends on investments in such fund, which generate tax free income and not receipt of that income?" The submission of the learned counsel appearing for the appellant is that the view taken by the....

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.... not earned any exempt income during the year under consideration. After consideration of Section 14A, the Delhi High Court followed decisions of certain other High Courts. Section 14A of the said Act provides that for the purpose of computing the total income, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the tot....