2021 (8) TMI 372

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....e find that by way of this Miscellaneous Application the contention of the Revenue is that ground No. 2 in the revenue's appeal remained to be unadjudicated. The submission read as under : "Ground No. 2: Addition of disallowance made u/s. 14A to book profits u/s. 115JB Brief facts The disallowance of Rs. 1, 84,26, 413/- calculated u/s. 14A was added to the book profits u/s. 1 15JB of the Act. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the addition made by the AO clause (f) of Explanation 1 to section 115JB. However, in alignment with his decision to reduce the quantum of disallowance u/s. 14A from Rs. 1,84,26,413/- to Rs. 16,98,745/-, the Ld. CIT(A) directed that the....

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....rder where assessee had also filed appeal, as under after noting the Assessing Officer's and learned CIT(A)'s order :- "20. We have heard both the counsel and perused the records. As regards disallowance on account of interest, we find that the learned CIT(A) has given the finding that assessee's own funds are sufficient to cover investment earning interest free income. The Assessing Officer has not disputed this claim of the assessee. He has held that the assessee has not been able to bring one- to-one nexus between the available interest free funds the investment earning exempt income. In this regard, we note that Hon'ble Jurisdictional High Court in the case of CIT vs HDFC Bank Ltd., 366 ITR 505 (Bom.) and CIT vs Relianc....