2019 (2) TMI 2089

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....JIT SINGH, ACCOUNTANT MEMBER:- This assessee's appeal for A.Y. 2012-13, arises from order of the CIT(A)-6, Ahmedabad dated 27-01-2017, in proceedings under section 143(3) of the Income Tax Act, 1961; in short "the Act". 2. The solitary ground of appeal of the assessee is against the decision of ld. CIT(A) in confirming the action of the assessing officer in disallowing Rs. 40,77,207/- u/s. 14A r....

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....d computed the allocation of expenses in relation to exempt income for the purpose of section 14A r.w. rule 8D of the income tax rule 1962 to the amount of Rs. 40,77,207/- and added to the total income of the assessee. 4. Aggrieved assessee filed appeal before the ld. CIT(A). The ld. CIT(A) has dismissed the appeal of the assessee. 5. During the course of appellate proceedings before us, ld. cou....

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....funds & Investments (A/B * 100) 5.97 times 7.13 times In this connection, the ld. counsel has also placed reliance on following judicial pronouncements:- CIT vs. Torrent Power Ltd. - 363 ITR 474 (Guj.) CIT vs. Suzlon Energy Ltd. - 354 ITR 630 (Guj) CIT vs. Gujarat Power Corporation Ltd. - 352 ITR 583 (Guj) CIT vs. Hitachi Home & Life Solutions (I). Ltd. - (2014) 41 taxmann.com 540 (....