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TMI Blog2016 (12) TMI 1731X X X X Extracts X X X X X X X X Extracts X X X X ..... sion of the Tribunal in assessee’s own case for A.Y. 2008-09 [2013 (11) TMI 364 - ITAT AHMEDABAD] as held that Provisions of Section 14A have wrongly been invoked in this case – Decided against the Revenue. - ITA. No: 653/AHD/2014 - - - Dated:- 23-12-2016 - SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER SHRI MAHAVIR PRASAD, JUDICIAL MEMBER Appellant by : Shri Prasoon Kabra, Sr. D.R. Respon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m of deduction of the assessee, the A.O. was of the opinion that provisions of section 14A squarely apply. As the assessee has not specified the expenses in relation to the investments, the A.O. computed the disallowance u/s. 14A r.w.r. 8D of the Act. The total disallowance was computed at ₹ 21225108//-. 5. Assessee carried the matter before the ld. CIT(A) and claimed that no disallowance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wn on the balance sheet of the assessee drawn as on 31st of March, 2008, wherein it was found that the paid up share capital was to the tune of Rs,37,05,88,000/- Our attention has also been drawn that the assessee had reserves another funds of ₹ 20,43,06,246/- as against that the investment in shares, NSC, KVP were at ₹ 8,17,57,010. On the basis of these Figures, the vehement contentio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... out of the computation of the total income. Those deductions are not like exempted income. So the argument is that the provisions of Section 14A are to be attracted in relation to income which does not form part of the total income, i.e., an income exempt under the Act. In this regard, a decision of ITAT Chennai Bench pronounced in the case of Tamil Nadu Silk Producers Federation Ltd. (supra) has ..... X X X X Extracts X X X X X X X X Extracts X X X X
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