2025 (9) TMI 1124

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....aised 11 grounds of appeal but they pertain to following two issues : (i) Disallowance u/s.14A of the Act at Rs.22,17,583/- (ii) Disallowance of Car related expenses at Rs.6,46,363/-. 3. Facts in brief are that the assessee is a Private Limited company and income of Rs.44,98,350/- declared in the return for A.Y. 2014-15 e-filed on 29.09.2014. The assessee company is engaged in the business of manufacturing and trading of Electronic and Electrical goods. Case selected for scrutiny through CASS followed by serving of statutory notices. Ld. Assessing Officer after considering the details filed by the assessee concluded the assessment proceedings by making additions totaling to Rs.30,58,946/- and assessed income at Rs.75,57....

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....e Bench Mumbai in the case of Kisan Ratilal Choksey Shares and Securities Pvt. Ltd. Vs. CIT (2015) 41 ITR 0114 (Trib) (Mumbai) and also that in the case of Edwise Consultants Pvt. Ltd. Vs. CIT in ITA No.594/Mum/2013 for A.Y. 2010-11. 7. On the other hand, ld. DR supported the orders of both the lower authorities. 8. We have heard the rival contentions and perused the record placed before us. First issue relates to disallowance u/s.14A of the Act. Ld. AO observed that the assessee had made huge investments in Equity shares and that in the balance sheet there are borrowed funds. Ld. AO applied Rule 8D of the Income Tax Rules, 1962 and computed the disallowance at Rs.22,17,583/-. We observe that during the year the assessee has earned ex....