9911796707
TMI Blog2019 (3) TMI 1032X X X X Extracts X X X X X X X X Extracts X X X X ..... WAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year [in short referred to as 'AY'] 2012-13 contest the order of Ld. Commissioner of Income-Tax (Appeals)-17, Mumbai, [in short referred to as 'CIT(A)'], Appeal No. CIT(A)-17/IT-90/15-16 dated 19/06/2017 on following grounds of appeal: - "The Commissioner of Income-tax (Appeals) - 17. Mumbai (hereinafter referred to as the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot to have been considered by the Assessing Officer/ CIT(A) per law and facts of the case." 2.1 The assessment for impugned AY was framed by Ld. Assistant Commissioner of Income Tax-10(3)(2), Mumbai [AO] u/s. 143(3) on 03/03/2015 wherein the income of the assessee was determined at Rs. 351.84 Lacs after disallowance u/s 14A for Rs. 14.82 Lacs as against returned income of Rs. 337.01 Lacs e-filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... first appellate authority deleted the interest disallowance of Rs. 9.30 Lacs by observing that own funds in the shape of Share Capital & Reserves far exceeded the investments made by the assessee. However, the expense disallowance of Rs. 8.52 Lacs was confirmed, against which the assessee is in further appeal before us. 3. The Ld. Authorized Representative for Assessee, agitated the additions on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o how those computations were not satisfactory. The failure to do so oust the jurisdiction of Ld. AO to apply Rule 8D. Another factor to be noted is that the said disallowance, considering exempt income yielding investments works out to Rs. 3.75 Lacs, against which the assessee has already offered suo-moto disallowance of Rs. 3 Lacs. Therefore, the net additional disallowance of Rs. 5.52 Lacs coul ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
