366/-
u/s.43B of the Act.
disallowance of unpaid sales tax of Rs.8,27,366/- u/s. 43B of the Act
requires
objection of the assessee disallowed an amount of 7,28,19,366 under
section 40(a)(ia) of the Act. Further, the Assessing Officer disallowed ... assessee has challenged disallowance of `
7,28,19,366 under section 40(a)(ia) of the Act.
8. As discussed in the earlier part
Acc Ltd., Mumbai vs Dcit(Ltu) - 1, Mumbai on 28 February, 2023
IN THE INCOME
Reliance Jio Infocomm Usa Inc.,Texas vs Dcit (It) 4 (1) (1), Mumbai on 17
Global Advisory Services Pvt. Ltd.,
had unequivocally held that no disallowance under section
14A was warranted in the absence of requisite satisfaction
and nexus ... Assesses
II] Suomoto Disallowance 2,06,263 7,78,768 4,38,366
u/s 14A made by the
Assessee
III] Disallowance
revenue
authorities. The assessee has challenged the additions
made by the AO u/s 68 and 69C of the Act, and in this
regard ... adding Rs. 72,96,366/-
u/s 68 of the Act.
6.2.1 During appeal proceedings, the appellant has made the similar
submissions as have been
under the Act;
-(vi) Even in the absence of sub-section (2) of Section
14A, the Assessing Officer would have to apportion
the expenditure ... endm ent whereby
the su b-section 2 of section 14A was brought into, the AO woul d
have to apportion the expenditure
held to be disallowable u/s. 40(i)(ia) as no TDS has
been deducted u/s. 194J. Regarding the other reimbursed expenses
since, they ... supra). Hence, out of total
disallowance of Rs. 56,37,366/- u/s. 40(a)(ia), disallowance amounting
to Rs. 12,96,751 is confirmed
action of the Assessing Officer in
levying penalty of Rs 60,366 under section 271B of
the Act.
2. The appellant contends that ... involved in this case i.e.
levy of penalty of Rs.16,366/- u/s. 271B of the Act. The facts
of the case
confirming, the disallowance of the proportionate Interest
expenditure of Rs. 92,27,366/- u/s. 36(1)(iii), incurred, allegedly in relation to
the funds ... prays that the disallowance of interest expenses of Rs.
92,27,366/- made u/s. 36(1)(iii) be deleted, while computing "Returned Loss