TaxTMI 
TaxTMI 
2021 (9) TMI 642
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....d in an affidavit dated 07.03.2019 filed by the Director of the assessee. It has been stated therein that at the time of due date for filing the appeal against the order of the CIT(A), the tax executive employed by the assessee who has been managing the representation before the lower authority left the services and was serving notice period. In the course of transition, some of the tax files were misplaced and one such file contained the impugned order of the CIT(A). The earlier tax executive did not inform the senior personnel of the assessee about the impugned order of the CIT(A). It was only when a notice under section 274 of the Income Tax Act, 1961 (Act) was received by the assessee for imposing penalty under section 271(1)(c) of the ....
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....he assessee is a joint venture between Mangalore Refinery and Petro Chemicals Ltd., and Shell Gas BV. The AO noticed that the assessee earned dividend income on investments. The AO also noticed that the assessee had incurred a sum of Rs. 22,40,000/- as other finance expense. The AO therefore proposed to invoke the provisions of section 14A of the Act and make a disallowance of interest and other expenses as per the provisions of section 14A of the Act r.w.r. 8D of the Rules. 7. In reply, the assessee submitted that it supplies AFT to customers like Air India, Jet Airways, etc., in selected domestic airports. The assessee also acts as contracting company for domestic carrier like Air India for meeting fuel requirements outside India. The ....
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.... been charged to the profit and loss account on account of such borrowings. Borrowings were made only to meet the short term cash deficit on the due date for discharge of liabilities. 8. The AO did not make any reference whatsoever to the aforesaid plea of the assessee and proceeded to apply the provisions of section 14A of the Act r.w.r. 8D of the Rules and determined the disallowance under section 14A at a sum of Rs. 18,11,700/- in the following manner: As per clause (1) Expenditure incurred directly towards earning tax exempt income -Nil As per clause (ii) A) Amount of interest expenditure which is not directly related to any particular income/receipt = Rs. 22,40,000/- B) Average value of i....
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....04-249 5 State Bank of India bank statement for FY 2011-12 250-266 11. In the application for admission of additional evidence, it has been submitted that in a letter dated 25.02.2016 filed before the AO, a specific stand was taken regarding the source of funds out of which investments yielded tax free income were made. Even in the proceedings before CIT(A), similar submissions were made but the CIT(A) decided the issue without calling for any documentary evidence to show that investments were made out of surplus funds. In these circumstances, the assessee has filed aforesaid application or admission of additional evidence. 12. We have considered the application for admission of additional evidence and are of the view that th....