2024 (11) TMI 1263

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...., Advocate For the Revenue : Shri Kanv Bali, Sr. DR ORDER PER S.RIFAUR RAHMAN, AM: 1. This appeal is filed by the assessee against the order of ld. Pr. Commissioner of Income-tax (PCIT), Delhi-1 (hereinafter referred to 'Ld. PCIT) dated 28.03.2024 for Assessment Year 2018-19. 2. The brief facts of the case are, the assessee had filed its return of income for assessment year 2018....

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....y the disallowance under Rule 8D of the Income-tax Rules, 1962 (for short 'the Rules) cannot invoke in the case of the assessee. In reply, the assessee submitted a detailed submissions vide letter dated 07.03.2024, the content of the letter is reproduced by the ld. PCIT at pages 5 to 7 of the impugned order. 3. After considering the detailed submissions of the assessee, he find it not tenable i....

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....neous nor prejudicial to the interest of revenue and Ld. Pr. CIT erred in invoking the provisions of section 263 and also erred in directing the ld AO to pass the order 263/143(3)/143(3A)/143(3B) and disallow the sum of Rs. 83,11,376/- u/s 14A of the Income Tax Act without properly appreciating the facts. 1.1 The Ld. Pr. CIT has erred both on facts and in law in ignoring the fact that the....

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.... the above said decision was overruled by Hon'ble Delhi High Court. Therefore, relying of above decision is not proper and justified. He prayed that the order passed by ld. PCIT deserves to be set-aside and prayed accordingly. 6. On the other hand, learned DR for the Revenue relied on the findings of ld. PCIT. 7. Considered the rival submissions and material placed on record. We observed tha....