2023 (1) TMI 1434

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Rai, Adv. Mr. Prithu Dudhoria, Adv. For the Appellant Mr.J.P. Khaitan, Sr. Adv. Mr. Ananda Sen, Adv. For the Respondent ORDER GA/1/2022 The Court : We have heard respective counsel for the either side. There is a delay of 577 days in filing the appeal. Upon perusal of the affidavit filed in support of the condone delay petition, we find that sufficient cause has been shown for not preferring....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s not necessary that exempt income should necessarily be included in a particular years income for disallowance to be triggered? The short issue which falls for consideration is whether the Assessing Officer has recorded his satisfaction while disallowing a sum of Rs. 15,60,72,830/- under Section 14A of the Act and invoking Rule 8D of the Income Tax Rules, for computation of the disallowance und....