2018 (9) TMI 1920

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....by the assessee is directed against the order dated 7.12.2016 passed by the learned CIT(A)-3, Mumbai and it relates to A.Y. 2011-12. The assessee is aggrieved by the decision rendered by the learned CIT(A) on following issues :- (a) Disallowance made u/s. 14A of the Act. (b) Charging of interest u/s. 234C of the Act. 2.We have heard the parties and perused the record. The asse....

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....d disallowed a sum of Rs. 13.18 lakhs. The learned CIT(A) also confirmed the same. 3.The Learned AR submitted that the assessee has invested its surplus funds in liquid scheme of mutual funds only, which does not require much analysis. He submitted that the dividend income is also either reinvested or received directly into the bank account. Accordingly he submitted that the assessee has not re....

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....uring the year under consideration, the assessee has made new investments in only two schemes. Since investment activity of the assessee is limited as stated above, in our view, the Assessing Officer was not justified in invoking provisions of Rule 8D of the I.T. Rules without recording dissatisfaction on the methodology adopted by the assessee. Considering low level of investment activity, we are....