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2020 (4) TMI 405

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..... sing Officer did not obtain the written approval of the concerned Commissioner before extending the scope of scrutiny in respect of disallowance under Section 14A - It is on record that the CBDT Instruction No.7/2014, dated 26-09-2014 did not permit the Assessing Officers to extend the scope of scrutiny to the issues other than the ones which are authorised by the Board in this regard under CASS. .....

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..... case and under the law, the Id. CIT(A) ought to had deleted the entire addition/disallowance of ₹ 33,03,808/- made u/s 14A read with Rule 8D. 2. That on the facts of the case and under the law, the Id. CIT(A) has erred in restricting the addition / disallowance made u/s 14A read with Rule 8D, to the extent of ₹ 4,27,000/- (which was the amount of dividend earned on the shares held .....

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..... shown from large gross receipt (vi) Large squared up loans during the year (form 3CD) (vii) Large Value sale of option in securities (derivative) in a recognized stock exchange (STT code4) The Assessing Officer assessed the income of the assessee at ₹ 36,62,178/- vide assessment order dated 30.12.2017 passed u/s 143(3) and made an addition / disallowance of ₹ 33,03,808/- u/s 1 .....

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..... l available on record. It is an undisputed fact that the reason for which the case was picked up for limited scrutiny relates to the AIR information on the cash deposits in the savings bank account. It is also an undisputed fact that the Assessing Officer did not obtain the written approval of the concerned Commissioner before extending the scope of scrutiny in respect of disallowance under Sectio .....

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