2014 (8) TMI 1137

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....d against order of ld. C.I.T.(A)- VI, Kolkata dated 23.11.2011 and pertains to Assessment year 2008-09. 2. The grounds of appeal in this appeal read as under :- "1. That in the facts and circumstances of the case the learned CIT(Appeal) was wrong in upholding the applicability of Rule 8D of the Income Tax Rule, 1962 contrary to its strict requirement and thereby erred in confirming the action of....

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....d the disallowance u/s 14A of the Act as per Rule 8D. AO computed the disallowance at Rs. 1,74,34,539/-. This had two components (i) allocation of expenditure by way of interest - Rs. 1,53,48,915/- (ii) ½% of the average of value of investment - Rs. 20,85,624/-. 4. Against the above order the assessee was in appeal before the ld CIT(A). Before the ld. CIT(A) the assessee submitted that the....

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....een disallowed by the assessee itself. The disallowance under section 14A Read with Rule 8D is hereby upheld in addition to the direct expenses in relation to the earning of exempted income, disallowed by the assessee itself. The appeal of the assessee is disallowed." Against the above order assessee is in appeal before us. 5. The ld. Counsel of the assessee submitted that the assessee has suffic....