TaxTMI 
TaxTMI 
2019 (4) TMI 1524
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....deep Kumar, Addl. CIT ORDER PER B.R. BASKARAN, AM: The assessee has filed this appeal challenging the order dated 28-07-2016 passed by Ld CIT(A)-7, Bengaluru and it relates to the assessment year 2008-09. The assessee is aggrieved by the decision rendered by Ld CIT(A) on the following issues:- (a) Disallowance u/s 14A of the Act. (b) Non-granting of credit for Foreign Tax. 2. We heard the ....
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....48.93 lakhs. Hence the AO, inter alia, reduced the loss by the amount of Rs. 155.83 lakhs disallowed by him u/s 14A of the Act. 4. In the first round of appellate proceedings before Ld CIT(A), the first appellate authority computed disallowance u/s 14A at Rs. 95.73 lakhs, which consisted of interest disallowance of Rs. 73.34 lakhs u/r 8D(2)(ii) and expenses disallowance of Rs. 22.39 lakhs u/r 8D(....
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....nt thereto, the assessing officer passed the assessment order u/s 143(3) r.w.s 254 of the Act on 31.03.2015, wherein he accepted that the investments (other than investment on which interest was voluntarily disallowed by the assessee) have been made out of past surplus funds. Accordingly he held no disallowance of interest expenditure u/r 8D(2)(ii) is called for. Accordingly he held that the expen....
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....he disallowance of Rs. 22.39 lakhs made by the AO in the consequential order is beyond the scope of remand made by the Tribunal and accordingly contended that the same should be deleted. On the contrary, the Ld D.R submitted that the above said disallowance of Rs. 22.39 lakhs was made by the Ld CIT(A) u/r 8D(2)(iii) in the first round itself and it has been accepted by the assessee in the first ro....