2025 (7) TMI 1054

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....r the Respondent : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018-19 arises out of an order of learned Commissioner of Income Tax (Appeals)-5, Ludhiana [CIT(A)] dated 19-04-2023 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 143(3) of the Act on 02-02-2021. The ....

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....r the purpose of MAT u/s 115JB. The assessee has ultimately paid taxes u/s 115JB. The Ld. CIT(A) confirmed the action of Ld. AO against which the assessee is in further appeal before us 3. The perusal of assessee's financial statements as placed on record would show that there is movement in trade investment portfolio of the assessee during the year. The opening investments are Rs. 80.56 Crores....

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....lable. The Ld. AO has applied Rule 8D and computed the indirect expense disallowance as per this rule only. Therefore, no fault could be found in the working of Ld. AO. Consequently, the impugned disallowance made while computing income under normal provisions stand confirmed. We order so. 4. So far as the adjustment thereof u/s 115JB is concerned, the same is not justified as per the decision ....