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2018 (10) TMI 1895
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....gayarkanni, JCIT. For the Assessee : None. ORDER Per S. Jayaraman, Accountant Member: The Revenue filed this appeal against the order of the Commissioner of Income Tax (Appeals)-3, Chennai in ITA No. 232/16-17/A-3 dated 27.10.2017 for assessment year 2014-15. 2. M/s. OPG Energy Pvt. Ltd., the assessee, is in the business of generation of power. In the assessment made for assessment ....
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.... was to be deleted as the assessee has not earned or received exempt income during the previous year relevant to assessment year under the appeal. 3. Aggrieved against that order, the Revenue filed this appeal on the following grounds: '1. The order of the Ld CIT(A) is contrary to law and facts and circumstances of the case. 2.1 The Ld CIT(A) erred in deleting the disallowance u/s. 14A r.....
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.... 2.4 The ld CIT(A) failed to note that the Board, vide Circular No.5 of 2014, has clarified that the disallowance is applicable even in cases where no exempt income was earned during the year, but there is a possibility of earning the 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 ....