2023 (7) TMI 513

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Agarwal a/w Mr. P.C. Tripathi for Mr. Raj Darak   P.C. 1. Three substantial questions of law are proposed in this Appeal and the same read as under: "(a) Whether on the facts and circumstances of the case and in law the Hon'ble the ITAT was right, in deleting the disallowance of Rs. 8,58,32,156/- under Section 14A r.w.s. Rule 8D without properly appreciating the factual an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... & legal matrix clearly broguth out in assessment order by the ld. Assessing Officer?" 2. At the outset, Mr. Suresh Kumar submitted that question (a) and (b) proposed are almost identical. 3. We admit the Appeal on the question (a) as under: (a)Whether on the facts and circumstances of the case and in law the Hon'ble the ITAT was right, in deleting the disallowance of Rs. 8,58,3....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... same was claimed against interest expenses of Rs. 12,39,80,822/-. The Assessing Officer concluded that the difference between income generated and interest paid is not allowable and hence, disallowed difference between Rs. 12,39,80,822/- and Rs. 8,70,00,000/- totalling to Rs. 3,69,80,822/-. 5. CIT (A) as well as ITAT have accepted that entire interest expenses of Rs. 12,39,80,822/- has to be a....