2018 (3) TMI 2064

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....ER PER G.S. PANNU, AM : The captioned appeal by the Revenue is directed against the order of CIT(A)-22, Mumbai dated 18.03.2016, pertaining to the Assessment Year 2011-12, which in turn has arisen from the order dated 20.03.2014 passed by the Assessing Officer, Mumbai under section 143(3) of the Income Tax Act, 1961 (in short 'the Act'). 2. In this appeal, Revenue has raised the following....

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....the Ld. CIT(A) on the above grounds be set aside and that of the Assessing Officer be restored." 3. The first Ground raised by the Revenue is against the action of CIT(A) in deleting the addition of Rs.1,56,94,709/- made by the Assessing Officer towards claim of ESOP expenses. 4. At the time of hearing, the learned representative for the assessee pointed out that the issue in dispute in Grou....

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....s appeal arises from the action of Assessing Officer in disallowing interest expenditure of Rs.15,86,995/- u/s 14A of the Act by applying the provisions of Rule 8D(2)(ii) of the Rules. 8. In this context, the relevant facts are that the assessee was found to have earned exempt income of Rs.42,83,080/- and assessee had suo moto disallowed a sum of Rs.25,84,454/- out of administrative/overhead ex....

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....unds. The CIT(A) also referred to the judgment of the Hon'ble Bombay High Court in the case of CIT vs HDFC Bank Ltd, 366 ITR 505 (Bom) and found it expedient to delete the disallowance. Against such a decision, Revenue is in appeal before us. 9. Although Revenue has contested the order of the CIT(A), but it is abundantly clear that no fault can be found with it in view of the judgment of th....