TaxTMI 
TaxTMI 
2025 (5) TMI 2047
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.... by the assessee is directed against the order dated 11.11.2024 of the Ld. Addl / JCIT(A)-11, Delhi relating to assessment year 2015-16. 2. Although a number of grounds have been raised by the assessee, however, these all relate to the order of the Ld. Addl / JCIT(A) in confirming the disallowance of Rs. 3,99,184/- made by the Assessing Officer u/s 14A of the Income Tax Act, 1961 (hereinafter ref....
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.... making addition of Rs. 3,99,184/- u/s 14A read with Rule 8D on the ground that no disallowance u/s 14A was made in the return although the assessee has huge investments. The explanation of the assessee that its own funds are more than fifteen times the investment in shares and that no part of borrowed funds are diverted for investment in shares, was rejected by the Assessing Officer. 4. In appea....
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....The Ld. DR on the other hand fairly conceded that the issue stands decided by the Special Bench of the Tribunal in the case of ACIT vs. Vireet Investment Pvt. Ltd. reported in 82 taxmann.com 415 (Delhi Tribunal) (SB). Therefore, he has no objection if the matter is restored to the file of the Assessing Officer with a direction to verify all the investments for considering the average value of the ....