2024 (5) TMI 1363

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....r passed under Section 143(3) on 26th December, 2019, by the ITO ward 2(4), Mumbai (the learned Assessing Officer), was partly allowed. 2. Therefore, the assessee is aggrieved with the same and has raised following grounds of appeal:- "1:0 Re: disallowance u/s 14A of the Income-tax Act, 1961 amounting to Rs.28,43,433/-. 1:1 The Commissioner of Income-tax (Appeals). Has erred in confirming the disallowance of Rs.28,43,433/- under Section 14A r.w.r 8D of the Income-tax Rules, 1962, while computing the appellant's total income for the year under consideration. 1:2 The Appellants submit that considering the facts and circumstances of its case and the law prevailing on the subject, no disallowance under Section 14A ....

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....(34) of the Income-tax Act, 1961 (the Act). On that basis, the return of income was filed on 1st August, 2017, at a taxable income of Rs.34,21,630/-. As the assessee has earned exempt income and has debited total expenditure of Rs.28,43,443/-, including interest of Rs.25,98,082/-, the learned Assessing Officer questioned about the provisions of Section 14A of the Act and disallowance therein. The assessee stated that it has earned exempt income of only Rs.3 lacs and has not incurred any expenditure to earn such income. The learned Assessing Officer rejected the contention of the assessee and computed disallowance under Section 14A of Rs.31,51,890/-. He restricted the disallowance to the extent of expenditure claimed of Rs.28,43,433/- and ac....