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TMI Blog2018 (9) TMI 1920X X X X Extracts X X X X X X X X Extracts X X X X ..... rder dated 7.12.2016 passed by the learned CIT(A)-3, Mumbai and it relates to A.Y. 2011-12. The assessee is aggrieved by the decision rendered by the learned CIT(A) on following issues :- (a) Disallowance made u/s. 14A of the Act. (b) Charging of interest u/s. 234C of the Act. 2.We have heard the parties and perused the record. The assessee-company is engaged in the business of manufacture an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also confirmed the same. 3.The Learned AR submitted that the assessee has invested its surplus funds in liquid scheme of mutual funds only, which does not require much analysis. He submitted that the dividend income is also either reinvested or received directly into the bank account. Accordingly he submitted that the assessee has not really incurred any expenditure for earning the dividend inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nvestments in only two schemes. Since investment activity of the assessee is limited as stated above, in our view, the Assessing Officer was not justified in invoking provisions of Rule 8D of the I.T. Rules without recording dissatisfaction on the methodology adopted by the assessee. Considering low level of investment activity, we are of the view that the disallowance of Rs. 2.19 lakhs made by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed income as per mandate of section 234C of the Act, after duly considering the advance tax paid by the assessee. According to the Ld A.R, there is mistake in the computation of interest. Hence, we restore this issue to the file of the Assessing Officer for examining the claim of the assessee by duly considering the returned income as well as advance tax paid by the assessee. 8. In the result, ap ..... X X X X Extracts X X X X X X X X Extracts X X X X
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