2025 (9) TMI 154

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....he Respondent : Shi Yogesh Mishra, S.DR ORDER PER: DR.BRR KUMAR, VICE PRESIDENT: This appeal has been filed by the Revenue against the order passed by the Ld. Commissioner of Income Tax(Appeal)/National Faceless Appeal Centre, passed for the Assessment Year 2017-18. 2. The grounds raised by the revenue are as follows: (a) The Ld.CIT(A) has erred in law and on facts in deleting....

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....taxation. The assessee has suo moto disallowed an amount of Rs. 17,21,177/- on account of expenses incurred for earning the exempt income. Not satisfied with the expenses disallowed by the assessee the Assessing Officer resorted to invocation of provision of section 14A read with Rule 8D and determined disallowance of an amount of Rs. 1,95,22,345/-. (212,41,07,335- 17,21,177). 4. Aggrieved, the....

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....ome Tax Rules. On the other hand, the Ld.AR argued that the Assessing Officer has no reason to invoke provisions of section 14(2) as the assessee has reasonably computed the disallowance on a scientific basis. 7. We have gone through the provision of the Act and the rationale of the disallowance determined by the assessee. We find that the assessee has considered the time utilized for purchase ....