2020 (2) TMI 1645

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....r the Revenue : Shri Kishan Vyas, CIT-D.R. For the Assessee : Shri Biren Shah, A.R. ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBER:- This assessee's appeal for A.Y. 2015-16, arises from order of the CIT(A)-1, Ahmedabad dated 28-08-2018, in proceedings under section 143(3) of the Income Tax Act, 1961; in short "the Act". 2. The revenue has filed appeal against the decision of ld. CIT(A....

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....uded in the total income. Therefore, vide notice u/s. 142(1) of the act the assessee was asked to explain why not provision of section 14A of the Act r.w.r. 8D of the I.T. Act should be attracted in the case of the assessee. The assessee has given detailed explanation reported at page no. 2 to 7 of the assessment order stating that assessee company has not earned dividend income or any other incom....

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.... On perusal of the decision of ld. CIT(A), it is noticed that the impugned addition has been deleted holding that assessee has not earned any exempt income which based on similar facts discussed in appellate order in the case of the assessee itself for assessment year 2014-15. While deleting the aforesaid addition, the ld. CIT(A) has also placed reliance on the decision of Hon'ble Gujarat High Cou....