2025 (3) TMI 2057

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....Dr ORDER PER SATBEER SINGH GODARA, JM This Revenue's appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1058552935(1), dated 07.12.2023 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 't....

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....rt to the Revenue's first and foremost substantive ground that the CIT(A) has erred in law and on fact in restricting the Assessing Officer's action making section 14A r.w.s. Rule 8D disallowance to the extent of assessee's exempt income amount of Rs. 51,09,431/- only. 4. Suffice to say, there could be hardly any dispute that the instant issue is no more res-integra in light of Joint Investment....

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.... to relate these expenses to have been incurred specifically for the purpose of the business or draw a relation for these expenses to bear business expediency. On the other hand, the appellant has stated that the directors of the appellant company have to travel to London and New York for planning and meeting relevant persons to create a diversified portfolio by investing in US and London Stock Ex....

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....r logbook could not be produced for personal expenses and business expenses, the Hon'ble ITAT had disallowed certain percentage of total expenses. Therefore, it appears to be justified if 5% of total such expense, i.e 5% of Rs. 1,78,65,066/-, which arrives at Rs. 8,93,253/- be disallowed to meet the ends of justice. The amount of disallowances is thus restricted to the said amount. The ground of a....