2018 (11) TMI 1424

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....mt. S. Praveena, DR ORDER PER Smt. P. Madhavi Devi, J.M.: This is assessee's appeal for the Assessment Year 2012 -13 against the order of the CIT(A), Guntur -1 dated 13.03.2018. the assessee has raised the following grounds of appeal: - "1. That the Ld. CIT(A) erred in directing the A.O. to recalculate the disallowance under Rule 8D(ii) instead of giving full relief as the appe l....

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....e facts and in the circumstances of the case and in law no disallowance could be made in under Rule 8D(2)(ii). 6. That on the facts and in the circumstances, the Ld. CIT(A) erred in directing the A.O. to apportion the remuneration of the Executive Directors and Non-Executive Directors to the shipping division. It is contended that the Executive Directors are in charge of specif ic busines....

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....e for the A.Y. 2011- 12 on 28/09/2012 declaring total income of Rs. 63,93,68,810/- after claiming deduction under Chapter VI -A of Rs. 2,25,19,122/-. Subsequently, the return was revised by the assessee on 25.03.2014 revising its income to Rs. 59,22,21,639/- after claiming deduction under Chapter VI -A of Rs. 6,26,92,533/-. During the assessment proceedings u/s 143(3) of the Act, the A.O. observed....

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....mitted that with regard to balance also where the assessee has huge and own sufficient funds to make investments, no disallowance u/s 14A is required to be made. In support of this contention, Learned Counsel for the Assessee placed reliance upon the decision of the Hon'ble High Court of Gujarat in the case of CIT vs. Suzlon Energy Ltd (354 ITR 630 (Gujarat). 6. Learned Departmental Representat....