2018 (4) TMI 23

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....bstantial question of law:- "Whether in the facts and circumstances of the case, the Hon'ble ITAT, Chandigarh is legally correct in deleting the addition of Rs. 19.70 crores (Rs. 7,03,49,029/- made under Section 143(3) + Rs. 12,67,00,000/-, made under Section 143(3) r.w.s 263) made on account of apportionment of expenses against exempted income under Section 14A of the Income Tax Act, 1961 read with rule 8D of the Income Tax Rules, 1962 when the revenue has not accepted the order of the Hon'ble High Court against quashing the order under Section 263 of the Income Tax Act, 1961 and SLP is recommended?" 2. A few facts relevant for the decision of the controversy involved as narrated in the appeal may be noticed. Assessment under Section 143....

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....f Rs. 7,03,49,029/-, the assessee filed an appeal before the Tribunal on this issue alongwith some other issues. The assessee also challenged the order under Section 263 of the Act passed by the CIT. Vide order dated 11.08.2016, Annexure A.5, the Tribunal deleted the addition made by the Assessing Officer under Section 143(3) of the Act amounting to Rs. 7.03 crores on account of apportionment of expenses against exempted income under Section 14A of the Act read with Rule 8D of the Rules and also set aside the order passed by the CIT under Section 263 of the Act. The department filed an appeal against this order before this Court which was decided against the revenue vide order dated 22.05.2017 in ITA No. 193 of 2017. The assessee also chall....