2017 (9) TMI 1751

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....he Act. 2. That the order of the Ld. CIT(A) is erroneous and is not tenable on facts and in law. 3. That the grounds of appeal are without prejudice to each other. 4. That the appellant craves leave to add, alter, amend or forego any ground(s) of appeal raised above at the time of hearing. 2. The brief facts of the case are that the assessee company is engaged in the business of generation and distribution of power. The company had taken a 27 MW Thermal Power Plant on Operating Lease w.e.f. March 2005 at Dalmiapuram, Distt. Tiruchirapalli and is operating the same. The assessee e-filed return of income declaring NIL income on 26/09/2011, which was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter re....

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....e is strictly to be made in terms of the specific provisions of Rule 8D. The assessee has offered the total dividend income as disallowance u/s 14A but it is not acceptable as computation under rule 8D. The assessee has not established with the necessary documentary evidence that it had not incurred any interest expenditure for the investment which has yielded dividend or shall yield such income and any other expenditure for earning exempted Dividend Income. The assessee has incurred interest expenditure and other expenditure during the year as well as earlier years and the exact quantum of expenditure for the year as well as earlier years could not be worked out. The disallowance u/s- 14A and as per Rule 8D is being made in the assessee&#3....