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TMI Blog2015 (7) TMI 741X X X X Extracts X X X X X X X X Extracts X X X X ..... oducts Limited v. ACIT (2012 (5) TMI 108 - ITAT, MUMBAI) the ITAT came to the conclusion that it was incumbent on the AO to have recorded that he is not satisfied with the correctness of the claim of the Assessee in respect of such expenditure which did not part of the income. It was held that in order to disallow the expenditure under Section 14A there must be a live nexus between expenditure inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hi Aggarwal, Sr Standing Counsel with Ms Lakshmi Gurung, Jr Standing Counsel. For the Respondent : None ORDER CM APPL No. 11275/2015 (for exemption) 1. Exemption allowed subject to all just exceptions. 2. The application is disposed of. ITA No. 368/2015 3. This appeal is directed against the impugned order dated 18th November 2014 passed by the Income tax Appellate Authority ('ITAT' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der, the ITAT allowed the appeal of the Assessee while dismissing the appeal of the Revenue. Relying on the decisions in Maxopp Investments Limited v. Commissioner of Income Tax 347 ITR 272 (Del) and Auchtel Products Limited v. ACIT 22 Taxman.com (1999) (Mum.) the ITAT came to the conclusion that it was incumbent on the AO to have recorded that he is not satisfied with the correctness of the claim ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nue. The Court is not prepared to permit the Appellant to urge a ground that was not raised before the ITAT. 7. Having considered the submissions of learned counsel for the Appellant and having examined the impugned order of the ITAT, the Court is not satisfied that any substantial question of law arises for determination in the facts and circumstances of the present case. 8. The appeal is dismi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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