2020 (12) TMI 654

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.... 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 year 2009-10 and completed the reassessment U....

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....sallowance 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 The learned CIT(A) has erred and held that the disallowance u....

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....t 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(A) may be set aside and that of the Assessing Officer be restored. 3. The case was heard thro....