2019 (7) TMI 354

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....ER PER VIKAS AWASTHY, JM : This appeal 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.....

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....ed funds for making the investments. Thus, there 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 a....

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....ial position has to be seen in each assessment year. 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....