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2020 (12) TMI 654
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....cate ORDER S. Jayaraman, Member (A) 1. The Revenue filed this appeal against the order of the Commissioner of Income Tax (Appeals)-9, Chennai in ITA No. 56 (2009-10) dated 20.09.2019 for the assessment year 2009-10. 2. M/s. Tamilnadu Petroproducts Limited, the assessee, is engaged in manufacturing and trading of petrochemical products. The AO reopened the assessment for the assessment ....
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.... average value of investment for computing disallowance as per third limb of Rule 8D(2) and accordingly directed the AO to recompute the applicable disallowance U/s. 14A r.w.r. 8D. Aggrieved against that order, the Revenue filed this appeal with the following grounds of appeal:- "1. The order of the learned CIT(A) is contrary to law and facts and circumstances of the case. 2.1 Th....
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....or disallowance u/s. 14A of the Act. 2.4 The learned CIT(A) failed to note that the CBDT has issued circular No. 5/2014 dated 11.02.2014 provides for disallowance of the expenditure even whether tax payer in a particular year has not earned any exempt income. 3. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(....