2019 (7) TMI 1487

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.... Shri D.G. Pansari ORDER PER SAKTIJIT DEY. J.M. Captioned appeal has been filed by the Revenue against order dated 15th March 2018, passed by the learned Commissioner of Income Tax (Appeals)-8, Mumbai, for the assessment year 2014-15. 2. The only dispute in the present appeal is with regard to deletion of disallowance made under section 14A r/w rule 8D. 3. Brief facts are, the asses....

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....ance under section 14A of the Act should be made. The Assessing Officer, however, did not find merit in the submissions of the assessee and proceeded to make a disallowance of Rs. 84,55,299, under rule 8D(2)(iii) towards administrative expenses. The disallowance made under section 14A r/w rule 8D was also added to the book profit computed under section 115JB of the Act. Being aggrieved of such ....

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....als) with regard to the computation of disallowance under section 8D(2)(iii) is fully in conformity with the ratio laid down in the Special Bench decision of the Tribunal, in case of CIT v/s Vireet Investment Pvt. Ltd., [2017] 82 taxmann.com 415 (Del.). In the aforesaid decision, the Special Bench of the Tribunal has held that while computing disallowance under rule 8D(2)(iii), only those investme....