2021 (9) TMI 596

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....ces & in law the learned Commissioner of Income Tax (Appeals) II Pune has erred allowing partial relief of Rs. 1,94,38,180/- as against disallowance of Rs. 2,06,49,222/- made by Assistant Commissioner of Income Tax Ahmednagar by invoking provisions of section 14A of IT Act. That the disallowance retained by CIT(A) II of Rs. 12,11,042/- is unwarranted & hence the addition made on account of disallowance U/s 14A of I.T. Act be deleted. 2) That the learned Commissioner of Income Tax (A) II Pune has erred on the facts & in the circumstances in confirming addition made by Assistant Commissioner of Income Tax Ahmednagar of interest U/s 244A of I.T. Act Rs. 3,38,468/-. That addition made by A.O. was unwarranted & hence the same be deleted....

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....me Tax Rules, 1962 ('the Rules). However, in respect of addition u/s. 14A, confirmed the addition u/s. 14A of the Act in respect of indirect expenses under clause (iii) of Sub-rule (2) of Rule 8D of the Rules. 5. Being aggrieved by the above decision of the ld. CIT(A), the appellant cooperative society is in appeal before us. 6. Ground of appeal no. 1 challenges the directions of the ld. CIT(A) confirming the addition in respect of indirect expenses under clause (iii) of Sub-rule (2) of Rule 8D of the Rules. It is submitted that while computing the disallowance under clause (iii) of Sub-rule (2) of Rule 8D of the Rules, the Assessing Officer had considered annual average of monthly average of opening and closing balance of value o....