2021 (10) TMI 282

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....This appeals is filed by the assessee against the order dated 26/02/2018 passed by CIT(A)-1, New Delhi for Assessment Year 2014-15. 2. The grounds of appeal are as under:- 1. On the facts and circumstances of the case, the order passed by the Id. CIT(A) (Appeals) is bad & erroneous in law. a) On the facts and circumstances of the case and in law, the Id. CIT(A), has erred in confirming the d....

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....icer to compute disallowance u/r 8D by considering the net interest paid after reducing the amount of interest income. d) That Id. CIT(A) further, erred in law and on facts in not restricting the disallowance u/r 8D read with section 14A of the Act, to the extent of exempted income of Rs. 4,77,220/- received by the Company. Directions be given to restrict the disallowance u/r 8D to the extent o....

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....The Ld. AR submitted that the CIT(A) erred in confirming the disallowance of Rs. 53,36,753/- u/s 14A read with Rule 8D as against receipt of total exempt income of Rs. 4,77,220/- (being dividend income of Rs. 4,42,693/- and exempt long term capital gain of Rs. 34,527/-) made by the Assessing Officer. The Ld. AR submitted that the Revenue should have computed disallowance under Rule 8D by consideri....