2021 (2) TMI 1296

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ngh, CIT/DR ORDER PER K. NARASIMHA CHARY, J.M. Challenging the order dated 28.09.2017 passed by the learned Commissioner of Income Tax (Appeals)-18, New Delhi ("the Ld. CIT(A"), for the assessment year 2013-14, Holtec Consulting Pvt. Ltd.("the assessee"), preferred this appeal. 2. Brief facts are that the assessee is engaged in the business of Technical and Management Consultancy. For ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... invoking section 14A read with Rule 8D is not sustainable. 4. Learned AR submitted that the authorities below failed to analyse the nature of investment as to whether the investment is yielding taxable income, exempt income or no income and that the satisfaction regarding the incorrect amount disallowed by the assessee was not recorded by the Assessing Officer. He, however, submitted that fact....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... to ones involved in assessment years 2009-10, 2010-11 and 2011-12, in which the issue was restored to the file of Assessing Officer to take a fresh view in the light of directions given in ITA No. 4563/Del/2012 for assessment year 2009-10, we are of the considered opinion that the request of the assessee can be accepted. We accordingly, while setting aside the impugned findings of the authorities....