claimed in the profit and loss account u/s.
40(a)(ia) read with Explanation (2) to section ... u/s. 14A by the assessee. Therefore, the Assessing Officer
applying Rule 8D calculated the disallowance u/s. 14A and disallowed
Rs.17,81,630
steam from eligible business
to other business amounting to ₹ 1,028,618,630/-. The rate at which
Page | 24
ITA Nos.755/Del/2022 ... assessee
would have used the cost plus method, the relevant deduction u/s
80 IA would have been much higher. Thereafter, the learned transfer
pricing
steam from eligible business
to other business amounting to ₹ 1,028,618,630/-. The rate at which
Page | 24
ITA Nos.755/Del/2022 ... assessee
would have used the cost plus method, the relevant deduction u/s
80 IA would have been much higher. Thereafter, the learned transfer
pricing
appeal of the assessee is against the disallowance
of ₹ 1,252,630 u/s 14A read with rule 8D of the income tax rules ... learned assessing officer to delete the disallowance of ₹ 1,252,630 made u/s
14 A of the act.
26. As we have already deleted
erred in law in sustaining an
addition of Rs.21,630/- under section 14A read with Rule
8D of the Act, to the extent ... Ground No. 2 is against sustaining the addition of Rs.21,630/-
u/s 14 A of the Act read with Rule
justified in confirming the addition of
Rs.1,09,630/- U/s 14 A of the Income Tax Act 1961 whereas as per
assessee ... 630
aggregate of (i), (ii) and (iii)
5.8 Hence, an amount of Rs. 1,09,630/- is disallowed
appeal of the assessee is
against the disallowance of 1,252,630 u/s 14A read with
17
rule 8D of the income tax rules ... learned assessing officer to delete
the disallowance of 1,252,630 made u/s On the given facts
of the case in hand and respectfully
Whether the provisions of section 147(b) Yes provisons of
are applicable or both the sections are Section 147 are
applicable/ applicable.
08 Whether ... negative
please state:
a) The income originally assessed Rs. 1,58,630/- u/s
143(3) on
31.12.2007.
b) Whether it is a case
Whether the provisions of section 147(b) Yes provisons of
are applicable or both the sections are Section 147 are
applicable/ applicable.
08 Whether ... negative
please state:
a) The income originally assessed Rs. 1,58,630/- u/s
143(3) on
31.12.2007.
b) Whether it is a case
appeal of the assessee is against the
disallowance of 1,252,630 u/s 14A read with rule 8D of the income
tax rules ... learned assessing officer to delete the
disallowance of 1,252,630 made u/s On the given facts of the
case in hand and respectfully
