2023 (6) TMI 214

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....or the Respondent : Shri V. Padmanaban, F.C.A. ORDER PER V. DURGA RAO, JUDICIAL MEMBER: This appeal filed by the Revenue is directed against the order of the ld. Commissioner of Income Tax (Appeals) 18, Chennai, dated 03.01.2023 relevant to the assessment year 2018-19. The only issue involved in this appeal is relating to deletion of disallowance made under section 14A of the Income Tax Act, 19....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....221 (Madras), the ld. CIT(A) directed the Assessing Officer to delete the addition of Rs.. 2,36,66,025/- made under section 14A of the Act. 3. Aggrieved, the Revenue is in appeal before the Tribunal. The ld. DR has submitted that when there is no express provisions in section 14A and Rule 8D, the ld. CIT(A) has erroneously restricted the disallowance. 4. On the other hand, the ld. Counsel for th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nvestment. Accordingly, by applying the provisions of section 14A r.w. Rule 8D, the Assessing Officer determined the disallowance at Rs.. 2,36,66,025/- and brought to tax. On appeal, the ld. CIT(A) directed the Assessing Officer to delete the addition towards disallowance made under section 14A of the Act. 6. In this case, the ld. CIT(A) has observed that in his assessment order itself, the Asses....