2025 (3) TMI 2097

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.... for condonation of delay. Whereas, the facts mentioned in the affidavit are reasonable and the Ld. DR has no specific objections. Accordingly, we condone the delay and admit the appeal. The assessee has raised the grounds of appeal challenging the order of the CIT(A) sustaining the additions made by the Assessing Officer. 3. The brief facts of the case are that, the assessee has filed the return of income on 30-11-2014 disclosing a total income of Rs. 8,31,650/-. Subsequently the case was selected for limited scrutiny under CASS and the notice u/sec 143(2) and u/sec 142(1) of the Act along with questionnaire are issued. In compliance, the Ld.AR of the assessee appeared from time to time and submitted the information and details. The Ass....

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....ggregating to Rs. 8,06,753/- and the assessee was called to substantiate that the expenses are incurred for business purpose. Whereas the A.O was not satisfied with the claims and observed that they are not incurred wholly and exclusively for the purpose of business and disallowed the claim. And (iv) the A.O find that the assessee has debited miscellaneous expenses aggregating to Rs. 2,36,745/- in respect of various expenses. The A.O dealt on the nature of expenses at Para 7.3 of the order and was not satisfied with the claim, which is not incurred for the business purpose and disallowed the expenses u/sec 37(1) of the Act. Finally the A.O has assessed the total income Of Rs. 8,31,650/- after setting of business loss and passed the order u/....

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....oking the submissions. On the first disputed issue, of disallowance u/sec 14A of the Act, the Ld.AR mentioned that the assessee has not incurred any expenses for earning exempt income and referred to the profit & Loss account, highlighting that the no expenses are debited and the investments are disclosed in the balance sheet. We find that these facts are similar to earlier years and in the latest decision of the Hon'ble Tribunal in the assessee own case for A.Y.2011-12 in ITA.No.203&204/PAN/2018 dated 6.04.2022 has restored the disputed issue of disallowance under section 14A of the Act to the file of the CIT(A). Further the Ld.DR has filed the status report dated 17-02-2025 of the Assessing Officer on this disputed issue of disallowan....