2020 (6) TMI 73

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.... For the Appellant : Shri Saroj Kumar Parida, Advocate For the Respondent : Shri AR.V. Sreenivasan, JCIT ORDER PER N.R.S. GANESAN, JUDICIAL MEMBER: This appeal of the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals)-11, Chennai dated 20.08.2019 and pertains to the assessment year 2017-18. 2. Shri Saroj Kumar Parida, the Ld. Counsel for the a....

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.... Madras High Court in Redington India Ltd., referred by the CIT(A) and nowhere the Apex Court over ruled the judgment of the Madras High Court in Redington India Ltd. The Ld.DR has also clarified that no exempt income was earned by the assessee during the year under consideration. 4. We have considered the rival submissions on either side and perused the material available on record. It is n....

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.... same previous year. Thus, by application of the matching concept, in a year where there is no exempt income, there cannot be a disallowance of expenditure in relation to such assumed income. (Madras Industrial Investment Corporation Ltd. vs. CIT (225 ITR 802)). The language of s.14A(1) should be read in that context and such that it advances the scheme of the Act rather than distort it." Simil....

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....cept to follow the judgment of the Madras High Court. There may be difference of opinion with regard to issues arises for consideration. Irrespective of the personal difference of opinion, the CIT(A) while deciding the appeal is bound to follow the judgment of the Apex Court and the jurisdictional High Court. Judicial discipline demand that all authorities in the State of TamilNadu and Pondicherry....