2014 (4) TMI 1287

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....inha ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been filed by the assessee against the order of the Commissioner of Income Tax (Appeals) [(hereinafter referred to as CIT(A)] dated 21.7.2011. 2. The sole ground raised in the appeal is with regard to the confirmation of disallowance of Rs.29,84,949/- u/s 14A of the Income Tax Act. 3. The Assessing Officer (hereinaf....

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....he AO. Aggrieved against the order of the CIT(A), the assessee has come in appeal before us. 6. Before us, the ld. Representative of the assessee has submitted that neither the assessee had earned any exempt income nor any expenditure had been incurred for earning of the exempt income. Moreover the assessee had his own sufficient funds for making the investments. He has further contended that t....

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....f such expenditure. However, a perusal of the assessment order reveals that the AO without recording any dissatisfaction with regard to the claim of the assessee that no expenditure was incurred by the assessee for earning the exempt income, straightway applied Rule 8D against the mandate of the provisions of section 14A of the Act. The ld. CIT(A) also ignored the contentions raised by the assesse....