2021 (9) TMI 1575

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... For the Applicant : Shri J. D. Mistri and Ronak Doshi For the Respondent : Smt. Smita Verma ORDER Per Saktijit Dey (JM)  Captioned application has been filed by the assessee seeking rectification of order dated 23-09-2019 passed in ITA No.779 /Mum/2014. 2. It is the contention of the learned counsel for the assessee that in the modified ground II, the assessee has raised a sp....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l has disposed of main grounds I and II, which are as under:- "GROUND I: Disallowance of interest u/s. 36(l)(iii) of the Act: 1. On the facts and in the circumstances of the case and in law, the Commissioner of Income Tax (Appeals)-14, Mumbai ["the CIT(A)"] erred in upholding the action of the Assistant Commissioner of Income Tax-6(l), Mumbai ["the AO"] in disallowing interest am....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....allowance made by the AO and to the extent sustained by the CIT(A) be deleted or substantially reduced." 5. Whereas, inadvertently, the Tribunal has not decided sub-ground 3 of additional/modified ground II filed on 06-07-2018, which reads as under:- "3. The Appellant humbly prays that in absence of any exempt income earned by the Appellant, no disallowance under section. 14A of the Ac....