2020 (2) TMI 1438

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....anian, CA For the Respondent : Smt. Sowmya Aacharya, Addl.CIT(DR)(ITAT), Bengaluru. ORDER Per N.V. Vasudevan, Vice President This appeal by the revenue is against the order dated 26.7.2019 of the CIT(Appeals)-I, Bengaluru relating to assessment year 2016-17. 2. The only issue that arises for consideration in this appeal is as to, whether the CIT(Appeals) was justified in deleting th....

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.... Interest expenses not directly attributable of any particular income or receipt then A X B / C* 2,69,28,714 (iii) 1/2 % of the average of the value of investments,  income from which does not or shall not form part of the total income. 26,32,400   Disallowance as per Rule 8D 2,95,61,114 4. With regard to the contention of assessee that in absence of ea....

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....er of AO and the CBDT Circular referred to by the AO in his order. 7. We have considered the rival submissions. We are of the view that in the light of the decision Hon'ble Delhi High Court in the case of Cheminvest Ltd., 378 ITR 33 (Del) and in light of the admitted factual position that the assessee did not earn any exempt income during the relevant previous year, the disallowance of expenses....