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TMI Blog2014 (7) TMI 1172X X X X Extracts X X X X X X X X Extracts X X X X ..... t the appeal has been filed by the assessee against the said consequential assessment order and the issue is only in relation to the computation of the average value of investment, the income from which does not form any part of the total income, we are of the view that the appeal filed by the assessee against the order passed under section 263 has become infructuous and consequently the same stan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the ld. CIT had invoked his power under section 263 against the original assessment order passed under section 143(3) on 17.09.2010 on the ground that while making the disallowance under section 14A, the provisions of Rule 8D had not been applied. Ld. A.R. drew our attention to the assessment order dated 17.09.2010 wherein in para 5 of the assessment order it was shown that the Assessing Offi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... consequential assessment order before the ld. CIT and the same is pending for disposal. It was the submission that the difference was only on account of the average value of investment as taken by the Assessing Officer and as taken by the assessee. It was the submission that the assessee has taken the average value of the investment, the income from which was not part of the total income, whereas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue is only in relation to the computation of the average value of investment, the income from which does not form any part of the total income, we are of the view that the appeal filed by the assessee against the order passed under section 263 has become infructuous and consequently the same stands dismissed. 6. In the result, the appeal of the assessee is dismissed. Order pronounced ..... X X X X Extracts X X X X X X X X Extracts X X X X
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