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TMI Blog2019 (2) TMI 1066X X X X Extracts X X X X X X X X Extracts X X X X ..... he Act, therefore, we delete the addition raised in view of the provision of section 14A read with Rule 8D of the Act and allowed the claim of the assessee. - Decided in favour of assessee. - I.T.A. No.5795/Mum/2017 - - - Dated:- 30-1-2019 - SHRI SHAMIM YAHYA, AM AND SHRI AMARJIT SINGH, JM For The Assessee : Shri Jeevraj P. Jain For The Revenue : Shri Chaudhary Arunkumar Singh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tuality. Appellant prays to consider that provision of section 14A are not applicable in case of appellant as income is exempt under principal of mutuality. 3. Learned CIT(A) erred in ignoring grounds of appeal that assessee should have claimed expenses disallowable u/s.14A against taxable income. Assessee by: Shri Jeevraj P. Jain Revenue by: Shri Chaudhary Arunkumar Singh Appellant prays th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) who confirmed the order of Assessing Officer, therefore, the assessee has filed the present appeal before us. ISSUE NO.1 TO 3:- 4. All the issues are interconnected, therefore are being taken up together for adjudication. In fact under these issues the assessee has challenged the addition of expenditure to earn the exempt income in sum of ₹ 2,51,638/- assessed by the Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee has also relied upon the memorandum of explanation of the provision of finance bill of 2001 provided the following rationale for insertion of section 14A of the Act. Certain incomes are not includible while computing the total income as these are exempt under various provision of the Act. There have been cases where deductions have been claimed in respect of such exempt income. This in eff ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he CIT(A) has wrongly confirmed the additions raised by the AO in view of the Section 14A read with Rule 8D of the Act, therefore, we delete the addition in sum of ₹ 2,51,638/- raised in view of the provision of section 14A read with Rule 8D of the Act and allowed the claim of the assessee. 8. In the result, the appeal of the assessee is Allowed. Order pronounced in the open court on t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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