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2018 (11) TMI 1424

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....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 llant's own f unds are f ar in excess of the amount....

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....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 business divisions and none of the Executive Directors are in charge of the shipping divisio....

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....g 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 that the assessee has made investments of Rs. 12,96,20,496/-, the income from which is exempt f....

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.... 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 Representative however supported the orders of the CIT(A). 7. Having regard to the rival contentions and the mat....