2021 (8) TMI 1190

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....d to as Act) dated 30/11/2018 by the ld. Circle 2(3)(1), Mumbai (hereinafter referred to as ld. AO). 2. The only issue to be decided in this appeal is as to whether the ld. CIT(A) was justified in confirming the disallowance made u/s.14A of the Act amounting to Rs. 5,35,981/- in the facts and circumstances of the instant case. 3. None appeared on behalf of the assessee. We have heard the ld. DR and perused the materials available on record. We find that the assessee is a private limited company deriving income from agriculture business, lease rent income and income from other sources. We find that the ld. AO had observed that assessee had earned income from agriculture as well as from non-agriculture division during the year. The rece....

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....same was not done according to the ld. AO. Apart from this, the ld. AO observed that assessee had incurred common expenses such as postage, courier and transportation etc which are also to be apportioned proportionately in the agri division. Additionally the assessee has not made any disallowance of expenses for managing the investments. So on going through the books of accounts of the assessee together with separate profit and loss account, the ld. AO finally proceeded to make disallowance u/s.14A of the Act r.w.Rule 8D(2) of the Rules in all the three limbs and arrived at the disallowance as under:- Under Rule 8D(2)(i) - Rs. 36,89,320/- Under Rule 8D(2)(ii) - Rs. 4,65,123/- Under Rule 8D(2)(iii) - Rs. 70,858/- ....