2025 (9) TMI 15

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....KEY, JM: This is an appeal preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter in short "the Ld.CIT(A)"), Delhi, dated 19.12.2023 for the Assessment Year (hereinafter in short "AY") 2014-15. 2. At the outset, it is noted that there is a delay of '139' days in filing of the appeal. And the AO/ACIT has filed an affidavit explaining the....

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....ee 'as to why' provisions of Sec.14A of the Act should not be applied for disallowing the expenditure incurred for the purpose of earning the exempt income. In response, assessee furnished certain explanations which was not accepted by the AO who applied Rule 8D of the Income Tax Rules, 1962 (hereinafter in short 'the Rules') and made disallowance of Rs. 69,69,630/- under the normal computation as....

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....that in the Original Assessment Order passed on 23.12.2016, he has inadvertently taken note of the interest expenditure of Rs. 5,47,10,000/- instead of the correct figures of Rs. 45,31,72,192/-. According to the AO, since the mistake was apparent on record, he passed a rectification order u/s.154 of the Act dated 28.06.2017 and recomputed u/s.14A disallowance at Rs. 3,81,69,675/-. Assessee being a....