2025 (1) TMI 1492

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....peals) ['CIT(A)'] erred on facts and in law in confirming action of the assessing officer in making disallowance under section 14A of the Income Tax Act, 1961 ('the Act') read with Rule 8D of the Income Tax Rules, 1962 ('the Rules'), albeit restricting the disallowance to Rs. 2,33,95,428 alleging the same to be incurred for earning exempt dividend income. 1.1 That the CIT(A) erred on facts and in law in holding that investment in unquoted shares were made during the year substantially out of the borrowed funds, without appreciating that the appellant had earned dividend income of Rs. 2,33,95,428 from mutual funds which were made from internal accruals and equity available with the appellant. 1.2 That the CIT(A) h....

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....ion about the correctness of the claim of the appellant in respect of the expenditure incurred for earning the said income. 1.9 Without prejudice, that the CIT(A) erred on facts and in law in, inadvertently, considering the amount of interest expenses at Rs. 7,86,55,443/- as against Rs. 2,08,15,484/-. 1.10 Without prejudice, that the CIT(A) erred on facts and in law in incorrectly computing the average value of total assets at Rs. 9,03,94,78,284 instead of the correct amount of Rs. 8,26,06,52,951. 1.11 Without prejudice, that the CIT(A) erred on facts and in law in incorrectly computing the amount of expenditure allegedly attributed to earning of exempt income at Rs. 4,43,46,901, albeit restricting it to Rs. 2,33,95,428, by applying r....