2025 (4) TMI 2170

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....an, Advocate For the Respondent : Ms. R. Anitha, Addl. CIT ORDER PER JAGADISH, A.M : A foresaid appeal filed by the assessee for Assessment Year (AY) 2011-12 arises out of the order of Learned Commissioner of Income Tax, Appeal, Chennai-16 [hereinafter "CIT(A)"] dated 22.11.2024 in the matter of assessment framed by the Assessing Officer [AO] u/s. 143(3) r.w.s 92CA of the Income-tax Ac....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nn.com 415 (Delhi - Trib.) (SB) it was held that only those investments which yielded exempt income during the year are to be considered for computing average value of investment. 3. Appellant craves leave to adduce additional grounds at the time of hearing." 3. The only ground of appeal in this appeal of assessee is against confirming the disallowance u/s. 14A r/w. Rule 8D(2)(iii) of ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g average value of investment for the purpose of disallowance under Rule 8D(2)(iii) of the Rules which has not been followed by A.O and Ld. CIT(A) and therefore, the A.O may be directed to compute the disallowance u/s. 14A as per the decision of Hon'ble ITAT, Delhi Benches. 5. On the other hand, the Ld. Departmental Representative (DR), has relied on the orders of lower authorities and argued t....