TaxTMI 
TaxTMI 
2021 (9) TMI 168
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..... The Ld. CIT (A) has erred on the facts and circumstances of the case in not appreciating the fact that AO made the disallowance in accordance with sec. 14A r.w.r 8D of the I.T Act only. 2. The Ld. CIT (A) has erred on the facts and circumstances of the case by deleting the addition made by the AO on account of disallowance of expenses on account of sale of content. 3. The Ld. CIT (A) has erred on the facts and circumstances of the case by deleting the addition made by the AO on account of software expenses. 4. The Ld. CIT (A) has erred on the facts and circumstances of the case by deleting the addition made by the AO on account of depreciation claim of software. 5. The Ld. CIT (A) has erred on the facts....
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....ITA No. 3124/Del/2018 A.Y. 2014-15: (Revenue) Disallowance u/s 14A: 4. During the year, the assessee earned dividend from mutual fund of Rs. 1,03,60,745/- and suo moto disallowed an amount of Rs. 5,57,215/- u/s 14A. The AO by resorting the provisions of Rule 8D(2)(ii) computed disallowance to Rs. 96,28,052/-. 5. The ld. CIT (A) directed the AO to recompute the disallowance u/s 14A by considering the investments from which dividend has been earned by the appellant company and relying on the order of the Special Bench of ITAT in the case of CIT Vs Vireet Investments Pvt. Ltd. 82 Taxman 415, we hereby direct that only the investments which yielded the exempt income be considered for computation of disallowance u/s 14A r.w. Rule 8D. ....
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....hardware is an integral part of the computer equipment, the issue has been repetitively held in favour of the assessee and since the ld. CIT (A) has followed the earlier orders of the Tribunal, we decline to interfere with the order of the ld. CIT(A). Legal & Professional expenses: 9. The assessee claim an expenses of consultancy charges of Rs. 12,94,46,194/- and 10,67,61,340/- under the head legal and professional expenses. The details of the expenses are as under: Consultancy charges Date Name Narration Amount Remarks 31/03/2014 RAJU & PRASAD CHARTERED ACCOUNTANTS FINANCE PROVISION 2012- 13_TDS RETURN, CERTIFICATES 120,752 Prior period expenses 31/03/2014 ERNST & YOUNG LLP FINAL MILESTONE_FI....
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....rein an amount of Rs. 21,39,865/- spent on account of merger expenses have been suo moto disallowed by the assessee. 11. On going through the entire facts, the ld. CIT (A) held that an amount of Rs. 6,00,000/- spent towards valuation of shares for the purpose of merger of the company and Rs. 5,50,000/- paid to independent consultant are in the nature of capital expenditure. 12. Since, the ld. CIT (A) has gone through the details of expenditure and since the assessee has already disallowed an amount of Rs. 21,39,865/-, we hereby hold that the grounds of appeal of the revenue on this issue cannot be sustained. ITA No. 2210/Del/2018 A.Y. 2014-15: (Assessee) 13. With regard to the amount of Rs. 6,00,000/- confirmed by the ld. CIT (A....