2020 (9) TMI 274

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ushili, Advocate For the Respondent : Shri. A R V Sreenivasan, JCIT ORDER PER S. JAYARAMAN, ACCOUNTANT MEMBER : The assessee filed this appeal against the order of Commissioner of Income Tax (Appeals)-1, Madurai, in ITA No. 101/2016-17 dated 28.01.2019 for assessment year 2013-14. 2. M/s. S. Annamalai, a big HUF. While making the assessment for assessment year 2013-14, the assessee ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rrowed loan only in the preceding assessment year i.e., in the assessment year 2012- 13 and the Income Tax Officer verified the nexus of the interest expenses with purchase of land and hence disallowed the entire interest expenditure of Rs. 9,46,855/- in the assessment made for the assessment year 2012-13 u/s. 143(3) dated 21.03.2015. The Assessing Officer has also failed to consider the facts tha....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., the assessee has not borrowed any loan towards any investment which earned exempt income and it has not claimed any interest expenditure as an expenditure from any of its income and therefore, section 14A r.w.r. 8D is not applicable. Since these aspects have not been examined, we are of the view that this issue requires a fresh examination. Therefore, we remit the issue back to the AO for a fres....