9911796707
TMI Blog2019 (7) TMI 1209X X X X Extracts X X X X X X X X Extracts X X X X ..... he ld. AR before us. We find that the assessee has been preferring this miscellaneous application for the second time on the very same issue without any substance and also trying to misuse the provisions of the Act by resorting to review of the order passed by this Tribunal in the guise of rectification. In our considered opinion, there is no mistake apparent on record within the meaning of Section 254(2) of the Act warranting any rectification as this Tribunal had duly addressed the arguments of the assessee and the intention behind introduction of Section 14A with rule 8D(2)(iii) in its order - Miscellaneous Application of the assessee is dismissed. - MA No.251/Mum/2019 (Arising Out of ITA No.5983/Mum/2013 - - - Dated:- 17-7-2019 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 77; 1,31,316/- vide its order dated 21.12.2018 by observing as under:- 3. We have heard the rival submissions. The Ld. AR pleaded that entire investments were made only out of own funds of the assessee in the form of share capital and free reserves which was several times more than the investments made by the assessee. Accordingly there cannot be any disallowance u/s 14A of the Act, He pleaded that the expenditure incurred were only the purpose of business and hence there is no need to make any disallowance u/s 14A read with Rule 8D of the IT Rules 'towards the indirect expenses. We find that the provisions of section 8D(2)(iii) of the IT Rules has been specifically brought in the Income Tax Rules only to take care of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es to prove the compliance made by the ld. AO of the decision rendered by the Hon ble Supreme Court in the case of Maxopp Investment reported in 402 ITR 640 which have been heavily relied upon by the ld. AR before us. We find that the assessee has been preferring this miscellaneous application for the second time on the very same issue without any substance and also trying to misuse the provisions of the Act by resorting to review of the order passed by this Tribunal in the guise of rectification. In our considered opinion, there is no mistake apparent on record within the meaning of Section 254(2) of the Act warranting any rectification as this Tribunal had duly addressed the arguments of the assessee and the intention behind introduction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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