2021 (8) TMI 934

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....kesh K Sehgal, CA ORDER PER K. NARASIMHA CHARY, JM. Challenging the order dated 7/9/2017 in appeal No. 10478/16-17 of CIT (A)-2 passed by the learned Commissioner of Income Tax (Appeals)-2, New Delhi ("Ld. CIT(A)"), in the case of M/s CL educate Ltd ("the assessee"), for the assessment year 2014-15, Revenue preferred this appeal on the following grounds:- 1. whether on facts and ....

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....g any income from the subsidiary company, out of investment. Learned Assessing Officer, however, recorded that the amount of proportionate interest as bearing to the amount of investment in the subsidiary company has to be disallowed and while working out the same under rule 8D of the Income Tax Rules1962 ("the Rules") he made an addition of Rs. 1, 27, 35, 364/-under section 14A of the Income Tax ....

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....le 8D of the Rules. We, therefore, do not find any ground to interfere with such findings and consequently confirm the same. Ground No. 1 of the Revenue's appeal is accordingly dismissed. 5. Now coming to the 2nd ground, according to the learned Assessing Officer, during the year, the loan balance of Rs. 1, 54, 88, 0 25/- due from Carrier Launcher Education Foundation (CLEF) was written off and....

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....ssee had declared the amount written off during this assessment year, as interest income in the earlier years and paid in taxes thereon. Since the assessee had declared the amount in question as income in the earlier assessment years and paid in taxes thereon, Ld. CIT(A) held that the conditions required under section 36(1)(vii) read with section 36 (2) of the Act. 7. It is not the case of the ....