TaxTMI 
TaxTMI 
2022 (6) TMI 1148
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.... Sr. D.R. ORDER Per Anil Chaturvedi, AM This appeal filed by the assessee is directed against the order dated 22.03.2019 of the Commissioner of Income Tax (Appeals)-33, New Delhi relating to Assessment Year 2014-15. 2. Brief facts of the case as culled out from the material on record are as under:- 3. Assessee is a company stated to be engaged in the business of dealing in share/securities. A....
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.... Ld. CIT(A) to the extent of Rs. 32,55,500/-, is highly excessive, primarily because the 'net' interest expenditure is required to be considered for working out the disallowance u/s. 14A." 5. During the course of assessment proceedings and on perusing the Balance Sheet, AO noticed that during the year under consideration, assessee had taken loans aggregating to Rs. 6.97 crores (rounded of....
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....mpt income. Aggrieved by the order of CIT(A) assessee is now in appeal before us. 6. Before us, Learned AR submitted that he has no grievance 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 submitt....
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....O be directed to work out the disallowance of interest under Rule 8D(2)(ii) on net interest expenditure. 7. Learned DR on the other hand did not controvert the aforesaid submissions made by Learned AR but however submitted that the necessary directions be given to Learned AO to work out the disallowance. 8. We have heard the rival submissions and perused the material available on record. The iss....