TaxTMI 
TaxTMI 
2021 (7) TMI 670
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....r dated 04.01.2018 passed by the Commissioner of Income Tax (Appeals)-42, New Delhi relating to Assessment Year 2012-13. 2. The relevant facts as culled from the material on records are as under: 3. Assessee is a company which is stated to be engaged in the business of marketing of manufactured fertilizers and retailed intermediate products, Export of processed meat products. Assessee filed its ....
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.... the purpose for making investment and earning tax exempt income thereon is an essential legal requirement? 3. Whether the term "in relation to" as used in section 14A of the Act contemplates a direct and proximate nexus between "expenditure incurred" and "earning of exempt income? 4. Whether the CIT(A) is correct in not upholding disallowance u/s. 14A of the Act without considering legislativ....
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....o decide the matter ex parte qua the assessee after considering the material on record and hearing the DR. Though various grounds have been raised by the Revenue, but however the issue involved is with respect to disallowance u/s. 14A of the Act. 5. AO noted that during the year under consideration assessee has made certain investments in shares and since those investments have yielded or may yie....
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....elete the addition he was swayed by the fact that assessee had not received any exempt income in the form of dividend from the investments and that the investment were made out interest free funds. He supported his decision by relying on the decision of Hon'ble Delhi High Court in the case of Cheminvest Ltd. vs. CIT [TS-5469-HC-2015 (DELHI)-O] and CIT vs. Taikisha Engineering India Ltd., (ITA ....