9911796707
TMI Blog2012 (8) TMI 581X X X X Extracts X X X X X X X X Extracts X X X X ..... Per V. Durga Rao, JM : This appeal filed by the Revenue and cross objection filed by the assessee are directed against the order passed by the CIT(A)-V, Chennai dated 19.04.2011 for Assessment Year 2007-08. 2. Brief facts of the case are that the assessee is engaged in the marketing of building materials, vehicle sales, governor service, travels and cargo, boat building, plantation and running w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowance of Rs. 11,42,607/- u/s 14A of the Act. A worksheet showing the detail on how the amount of disallowance for Rs. 11.42.607/- had been arrived at has also been submitted. Accordingly, the Assessing Officer has disallowed Rs. 11,42,607/- u/s 14A of the Act and the same was added to the total income of the assessee. Aggrieved, the assessee carried the matter in appeal before the ld. Comm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax( Appeals). 6. We have heard the rival submissions and perused the orders of the authorities below as well as the material available on record. The only dispute in this appeal is whether the ld. Commissioner of Income-tax(Appeals) is right in directing the Assessing Officer to disallow 2% of the dividend income or not? However, the ld. Commissioner of Income-tax(Appeals), without considering ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... determine the expenditure which has been incurred in relation to income which does not form part of the total income under the Act. The AO must adopt a reasonable basis or method consistent with all the relevant facts and circumstances after furnishing a reasonable opportunity to the assessee to place all germane material on the record. The proceedings for assessment year 2002-03 would stand rema ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 'ble Jurisdictional High court after providing reasonable opportunity of being heard to the assessee. This ground of appeal of the Revenue is allowed for statistical purposes. 8. The cross objection filed by the assessee is in support of the order of the ld. Commissioner of Income-tax(Appeals). In view of our decision given above in Revenue's appeal, this ground of appeal raised by the assessee h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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