2020 (8) TMI 123

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.... PER BHAVNESH SAINI, J.M. This appeal by Revenue has been directed against the Order of the Ld. CIT(A)-7, New Delhi, Dated 12.06.2017, for the A.Y. 2014-2015, challenging the deletion of disallowance of Rs. 4,34,68,736/- made by A.O. under section 14A read with Rule 8D of I.T. Act, 1961. 2. We have heard the Learned Representatives of both the parties through video conferencing and perused th....

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.... made the disallowance under section 14A read with Rule 8D of the impugned amount. 3. The assessee challenged the addition before the Ld. CIT(A). The assessee apart from challenging the addition on merit as well as submitted before the Ld. CIT(A) that since assessee company did not receive any dividend income during the year, no further disallowance under section 14A can be made in the case of as....

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....rcular on the proposition that even under such circumstances when no dividend income has earned, addition could be made under section 14A because the A.O. is bound by the mandatory provisions of Rule 14A read with Rule 8D(2) of the I.T. Act, 1961. Since it is an admitted fact that no dividend income is earned by assessee in assessment year under appeal which fact is clearly mentioned in the Orders....