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TMI Blog2019 (5) TMI 639X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome Tax-I, Chandigarh v. M/s Vardhman Chemtech Private Limited, Chandigarh [ 2018 (10) TMI 1037 - PUNJAB AND HARYANA HIGH COURT] wherein the appeal filed by the revenue was dismissed. - ITA-254-2018 (O&M) - - - Dated:- 3-5-2019 - MR AJAY KUMAR MITTAL AND MRS MANJARI NEHRU KAUL, JJ. For The Appellant : Mr. Rajesh Katoch, Sr. Standing Counsel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Income Tax Rules, 1962 by ignoring the Circular No. 5/2014 dated 11.02.2014 issued by the CBDT which provides for disallowance of expenditure even where tax payer in particular year has not earned any exempt income? ( ii) Whether the impugned order dated 12.12.2017 passed by the Hon'ble ITAT is sustainable in the eyes of law and maintainable in the facts and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e investments as declared were capital in nature and the income, if any, arising by way of dividend, out of such investment was exempt from taxation. The assessee had not offered any disallowance of expenditure in this regard. The Assessing Officer vide assessment order dated 18.3.2015 (Annexure A-I) made a disallowance of ₹ 32,17,309/- under Section 14A of the Act read with Rule 8D of the I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n judgment in the case of the same assessee for the assessment year 2007-08 and also relying upon the judgment of this Court in CIT v. Winsome Textiles (2009) 319 ITR 204 (P H) and judgments of other High Courts. Hence, the present appeal by the revenue against the deletion of disallowance made under Section 14A of the Act. 3. We have heard learned counsel for the revenue. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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