2021 (9) TMI 1248

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....r referred to as 'the assessee') by filing the present appeal sought to set aside the impugned order dated 27.12.2017 passed by the Commissioner of Income - tax (Appeals)-7, New Delhi qua the assessment year 2012-13 on the grounds inter alia that:- "That on the facts and in the circumstances of the case and under the provisions of law, the Commissioner of Income Tax (Appeals) has erred i....

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.... the AO by invoking the provisions contained u/s. 14A read with Rule 8D made disallowance of Rs. 40,82,567/- out of which assessee has already made suo motu disallowance of Rs. 25,53,238/- and balance amount of Rs. 15,29,329/- is added back to the income of the assessee. 3. Assessee carried the matter before the ld. CIT(A) by way of filing appeal who has dismissed the appeal u/s. 250(6) of the Ac....

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....ven, operative part of the findings returned by the ld. CIT(A) are as under:- "3.2 I have carefully considered the assessment order and the submissions filed by the ld. AR. The CIT (Appeals)-16 has allowed relief to the appellant vide order No. 143/2016-17 (Old appeal No. 228/2015-16) dated 06.12.2016 and appeal effect already allowed to the appellant. Therefore, the disallowance u/s. 14A of the....