AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
2017 (10) TMI 1647
X X X X Extracts X X X X
X X X X Extracts X X X X
....For the Respondent : Mr.Saroj Kumar Parida, Adv. ORDER PER GEORGE MATHAN, JUDICIAL MEMBER: ITA No.331/Mds/2017 is an appeal filed by the Revenue against the Order of the Commissioner of Income Tax (Appeals)-8, Chennai, in ITA No.65/2015-16 dated 21.11.2016 for the AY 2012-13. 2. Mr.M.Palanichamy, JCIT, represented on behalf of the Revenue and Mr.Saroj Kumar Parida, Adv. represented on ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Para No.11 & 12 which has been held as follows: 11. The Kolkata Bench of this Tribunal in REI Agro Ltd. Vs. DCIT (supra) held that disallowance under section 14A read with Rule 8D can be made only by taking into consideration the investments which has given rise to such income which does not form part of the total income. While holding so, the Tribunal observed as under:- "8. In ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....is to be in relation to the income which does not form part of the total income and this can be done only by taking into consideration the investment which has given rise to this income which does not form part of the total income. Under the circumstances, the computation of the disallowance under section 14A read with rule 8D(2) (iii) which is issue in the assessee's appeal is restored to the fil....