2022 (6) TMI 1148

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.... 3. Assessee is a company stated to be engaged in the business of dealing in share/securities. Assessee electronically filed its return of income for A.Y. 2014-15 on 29.11.2014 declaring total income of Rs. 27,86,283/-. The case was selected for scrutiny and thereafter assessment was framed u/s. 143(3) of the Act vide order dated 13.12.2016 and the total income was determined at Rs. 72,21,667/-. 4. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 22.03.2019 in Appeal No. 470/17-18 granted partial relief to the assessee. Aggrieved by the order of CIT(A), assessee is now in appeal before Tribunal and has raised the following grounds (modified grounds) of appeal: "That on the facts of th....

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....ce as far as the disallowance under Rule 8D(iii), being administrative expenses, at one-half percent of average value of investment is concerned. The only grievance is with respect to the calculation of disallowance of interest under Rule 8D(2)(ii). He submitted that during the year under consideration assessee had earned interest income aggregating to Rs. 1,43,14,662/- as reflected in Note No. 16 & 17 of the financial statements which is placed at page 12 of the paper book and had incurred interest expenditure to the extent of Rs. 1,65,42,226/- meaning thereby that the net interest expenditure incurred by assessee is to the extent of Rs. 22,27,564/-. He therefore submitted that the disallowance under Rule 8D(2)(ii) be worked out on the bas....