2019 (4) TMI 351

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....2013-14. The only effective ground raised in the appeal of the Revenue is that the ld. CIT(A) has erred in deleting the disallowance made under section 14A of the Income Tax Act, 1961 ["Act" in short]. The assessee also filed an appeal against the order of the ld. CIT(A) 6, Chennai dated 30.01.2018 relevant to the assessment year 2012-13 challenging the ex-parte order without deciding the issue on merits. I.T.A. No. 1266/Chny/2018 [AY 2013-14] 2. Against the deletion of disallowance made under section 14A of the Act r.w. Rule 8D, the ld. DR has submitted that the ld. CIT(A) erroneously deleted the disallowance as there is no exempt income, when there is no such exception provided in Rule 8D. It was the submission that the CBDT has clarifi....

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....rategic investment and has been made out business expediency and not with an intention of earning any dividend income. It was further submitted before the Assessing Officer that the assessee has not earned any dividend income from ASPI. However, the Assessing Officer has observed that the investment made by the assessee is not an "invest-and-forget" activity and requires monitoring. Since the assessee does not have a dedicated division or personnel for this work, the existing personal will have to be deployed for this work. Therefore, some portion of the resources of the company would have to be diverted for this purpose. Therefore, after recording the reasons, the Assessing Officer determined the expenditure incurred in relation to income ....