2019 (7) TMI 354

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....l by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-4, Pune dated 10-10-2016 for the assessment year 2012-13. 2. Mrs. Anita Singh appearing on behalf of the assessee submitted that the solitary issue raised in appeal by the assessee is with respect to disallowance made u/s. 14A r.w. Rule 8D(2)(ii) of the Act. The ld. AR submitted that the assessee is a private ....

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....e is no question of making disallowance u/s. 14A with respect to interest expenditure. The ld. AR submitted that similar disallowance on account of interest expenditure u/s. 14A was made in assessment years 2008-09 and 2010-11. The issue travelled to the Tribunal. The Tribunal in ITA No. 638/PUN/2017 for assessment year 2008-09 decided on 28-09-2018 and ITA No. 137/PUN/2015 for assessment year 201....

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..... 4. Both sides heard. Orders of the authorities below perused. The assessee in appeal has raised single issue assailing disallowance of Rs. 12,08,801/- u/s. 14A r.w. Rule 8D(2)(ii) of the Act. The ld. AR has drawn our attention to the Balance sheet as on 31-03-2012 at page 7 of the paper book. A perusal of Balance sheet shows that the assessee is having own interest free funds comprising of shar....