2023 (11) TMI 1403

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....Sh. M.P. Dwivedi, Sr. DR ORDER PER N. K. BILLAIYA, AM: This appeal by the assessee is preferred against the order of the CIT(A)-6, Delhi dated 10.06.2018 pertaining to A.Y. 2016-17. 2. The solitary grievance of the assessee is that the CIT(A) erred in confirming the disallowance made u/s. 14A read with rule 8D of the Act by the AO. 3. The assessee filed its return of income declarin....

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....pletely ignored the suo-moto disallowance made by the assessee. The Counsel drew our attention to the decision of the cordinate Bench in ITA No.6526/Del/2019 wherein the Tribunal has held that when exempt income is from investment in subsidiary there is no justification to attribute any direct or indirect expenses by the assessee. 8. Per contra the DR strongly supported the findings of the AO a....