2018 (4) TMI 521

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..... the Respondent : None ORDER The question of law urged is identical to what was urged by the Revenue in ITA 81/2018 and ITA 83/2018 (Principal Commissioner of Income Tax (Central)-1 v. M/s Moonstar Securities Trading and Finance Co. Pvt. Ltd.) with respect to disallowance under Section 14A of the Income Tax Act, 1961 (hereafter referred to as "the Act"). The additions were made in the course of .....

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..... induced the assessee to offer particular amount as expenditure with some reasoning, the mere rejection per se cannot be accepted. In this case for both years, the assessee had offered amounts as disallowance claiming them to be expenditure for tax exempt income. The Assessing Officer merely proceeded to reject such amount as expenditure and straightaway applied Rule 8D without adducing any reasons .....

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