2022 (7) TMI 782

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....ent by: Shri Sita Ram Meena , Sr. D. R. ; ORDER PER YOGESH KUMAR U. S. , JM This appeal has been filed by the assessee against the order dated 11/03/2019 passed by CIT(A)-9, New Delhi for Assessment Year 2015-16. 2. The grounds of appeal are as under:- "That on the facts and law involved the Ld. Commissioner of income Tax (Appeals) [Ld. CIT(A)] erred in upholding the disallowa....

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....e Ld. CIT(A) are against law and facts of the case involved. 5. That the grounds of appeal as herein are without prejudice to each other. 3. Brief facts of the case are that, the assessee is a Company registered under the Companies Act and engaged in the business of manufacturing, exporters and importers, traders, representatives consultants, distributions buyers and sellers of home fu....

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....e in investment yielding tax free income. There is no increasing investment rather there was a huge decrees. Since, the assessee has own interest free funds. Therefore, no disallowance can be made. But both the Assessing Officer and CIT(A) have rejected the said contention and sustained the disallowance of expenditure under Rule 8D(2) of Rs. 2,92,018/-. The Ld. Counsel for the assessee further sub....

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....016 vide order dated 24/02/2020, wherein it is held as under:- "14. From the above, it can be deciphered that Rule 8D is not mandatory, the Assessing Officer must record his satisfaction that he is not satisfied with the correctness of the claim of the assessee in respect of such expenditure for cogent reasons. Satisfaction of the Assessing Officer has to be arrived at, having Taurus Home....