2021 (1) TMI 734

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....mal, Sr. DR ORDER Sudhanshu Srivastava, Member (J) This appeal is preferred by the assessee against order dated 22.09.2016 passed by the Learned Commissioner of Income Tax (Appeals)-37, New Delhi {CIT(A)} for Assessment Year 2013-14. The only issue under challenge is the upholding of the disallowance of Rs. 8,28,036/- u/s. 14A of the Income tax Act, 1961 (hereinafter called 'the Act&#....

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....ee is before this Tribunal challenging the upholding of the impugned disallowance. 4. The Ld. Authorized Representative (AR) submitted that the Assessing Officer had made the impugned disallowance in terms of provision of Rule 8D(2) (iii), which was incorrect because there was no opening and closing balance of investments in the assessee's books on the first day and the last day of the year....

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....e records, we note that the Assessing Officer has mentioned specifically in para 3.3 of the assessment order that the assessee has suo motu disallowed an amount of Rs. 67,853/- as disallowance u/s. 14A of the Act. Although, the Ld. Authorized Representative has argued that no such suo motu disallowance was made by the assessee in its computation of income, for want of evidences we cannot look into....