erred in deleting the
addition made without appreciating the provisions of
section 14A and without considering the specific
clarification issued in this regard ... contention of the assessee that in the absence of
dividend income, section 14A is not applicable relying upon the decision
of Special Bench
purpose determination of Total Income, and hence the vires of
section 14A does not contemplate any disallowance
consequent to income arising from stock in trade ... raised many
contentions. Firstly, it was stated that no disallowance under
section 14A of the Act is called for in view of the earlier order
exempt income was earned the disallowance made
under section 14A was also directed to be deleted.
4. Aggrieved by the same both the Assessee ... erred in holding that the provisions of Section 14A as
clarified by CBDT Circular No. 5 of 2014, were not attracted as the assessee
exempt income was earned the disallowance made
under section 14A was also directed to be deleted.
4. Aggrieved by the same both the Assessee ... erred in holding that the provisions of Section 14A as
clarified by CBDT Circular No. 5 of 2014, were not attracted as the assessee
Income Tax in his order
under section 263 of the Act. The disallowance under
section 14A of the Act though has been considered ... Explanation-1 to section 263(1) of the
Act is the term "matter". The issues relating to sections
14A
ground Nos.1 and 2 relates to disallowance
under section 14A of the Income Tax Act, 1961 (in short
'the Act'), which read ... applying provisions of
section 14A of the Act read with Rule 8D of the Income Tax
Rules. The assessee had earned dividend income
appellant further
submitted that as per sub section 2 & 3 in section 14A
effecting from 01.04.2007, the AO shall follow the
prescribed method only ... Assessing Officer in the rectification proceedings under
section 154 raised the issue of disallowance under
section 14A and considered the details from the Profit
passing the order
under section 143(3) of the Act and, therefore, not made
disallowance of interest under section 14A of the Act with
regard ... notice under section 154 dated
10.3.2014 issued by the Assessing Officer asking the
assessee why not a disallowance under section 14A
learned CIT (Appeals) in deleting the disallowance of
expenses made under section 14A of the Act to the tune ... other expenses
amounting in all to Rs.3,16,191/- under section 14A of
the Act r.w.s. 8D(ii() & (iii) on account
made by Assessing Officer under section
14A applying Rule 8D of the income Tax Rules.
2
2. Both the parties mainly argued in assessment year ... lacs and so he worked out
the disallowance under section 14A at Rs.22,45,649/-
and made the addition
