2021 (7) TMI 516

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....ICE HEMANT CHANDANGOUDAR APPELLANTS: SRI K.V. ARAVIND, ADVOCATE RESPONDENT: SRI A. SHANKAR, SENIOR COUNSEL AND SRI M. LAVA, ADVOCATE JUDGMENT Mr.K.V.Aravind, learned counsel for the revenue. Mr.A. Shankar, learned senior counsel for the assessee. This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the rev....

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....y attributed to any particular income or receipts, provisions of Rule 8D (2) (ii) are automatically applicable ? b) Whether the Tribunal was correct in considering the Board's circular No.5/2014 dated 11.02.2014 which has made it clear that the disallowance u/s 14A r.w.r. 8D has to be made even where the tax payer in a particular year has not earned any exempted vis-a-vis dividend inc....

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.... 4. The assessee as well as the revenue filed appeals against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] before the Tribunal. The Tribunal vide order dated 12.09.2014 allowed the appeal preferred by the assessee and dismissed the appeal preferred by the Revenue. 5. The learned senior counsel for the respondent submitted that the substantial questions of law involved in this....