2022 (12) TMI 280

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....assed by the CIT(A) through Income Tax port. The delay involved was not intentional nor deliberate but due to old age and physical limitation of the Director of assessee by name Ashok Nandlal Baser. The ld. AR submits that the assessee was in compliance of all the procedures but however due to old age of Director the delay of 972 days crept unfortunately. Further, he submits that the age of said Director is around 80 years and contesting the similar issue for A.Y. 2009-10 and drew our attention to the order dated 17-05-2018 in ITA No. 176/PUN/2016 in assessee's own case at page 8 of the paper book. The ld. AR argued that the assessee has no deliberate intention in filing the appeal belatedly but however the age concerning of Director the de....

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....on that the assessee did not apportion any expenditure relating to the exempt income and not satisfied with the claim of assessee that no expenses were incurred to earn its exempt income, proceeded to work out by applying Rule 8D, disallowed expenditure of Rs.1,78,490/- and Rs.5,40,395/- under Rule 8D(ii) & (iii), respectively. The AO clearly recorded its non-satisfaction with regard to accounts of assessee in para 4 of the assessment order. The CIT(A) confirmed the view of AO recording of non-satisfaction regarding the accounts of assessee. On perusal of finding of AO regarding recording of non-satisfaction with regard to accounts of assessee relating to exempt income, I do not find any infirmity in the order of CIT(A) in holding that the ....