2025 (3) TMI 2253

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....peal against the Assessment Order, dated 25/02/2021, passed under Section 143(3) of the Income Tax Act, 1961 for the Assessment Year 2018-19. 2. The Revenue has raised following grounds of appeal : "i. "Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in restricting the addition done by the AO u/s 14A of the Act as per Rule 8D of the Income tax Rules without appreciating the fact that the arrangement given is only section 44 is applicable on insurance company and has an over-riding effect on other sections where the assessee cannot take the benefit of section 10 as well as section 44?" ii. "Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in restricti....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d not be applicable to the Assessee-company engaged in insurance business in view of the specific provisions contained in Section 44 of the Act. We find that the CIT(A) has deleted the disallowance made by the Assessing Officer under Section 14A of the Act by placing reliance upon the aforesaid decision of the Co-ordinate Bench of the Tribunal the relevant extract of which reads as under: "7. We have considered the submissions of the parties and perused the material available on record in the light of the decisions cited before us. Undisputedly, the assessee is engaged in the business of life insurance. The Assessing Officer himself in the assessment order has observed that profits of the assessee has to be computed in terms of sec....