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TMI Blog2020 (4) TMI 849X X X X Extracts X X X X X X X X Extracts X X X X ..... [ 2016 (8) TMI 1009 - ITAT PUNE] is not helpful to the assessee as the facts in both the case law are different. The assessee in this case was aware about the disallowance under section 14A, which was not hesitated by him by filing appeal before first appellate authority. No merit in the grounds of appeal raised by assessee. - ITA No. 6609/Mum/2018 - - - Dated:- 24-2-2020 - Shri R.C. Sharma, Accountant Member And Shri Pawan Singh, Judicial Member For the Appellant : None For the Respondent : Shri Satishchandra Rajore (DR) ORDERUNDER SECTION 254(1)OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER; 1. This appeal by assessee is directed against the order of ld. Commissioner of Income Tax (Appeals)-53, Mumb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sists of interest disallowance of ₹ 1,56,697/- and indirect disallowance @ .5% of average value of investment of ₹ 3,224/- thereby total disallowance of ₹ 1,59,931/-. No first appeal was filed by assessee within period of limitation. The assessee filed appeal before the ld. CIT(A) only on 27.02.2017. The appeal was filed after 1927 days of prescribed period of limitation. In support of condonation of delay, the assessee stated before ld CIT(A) that the assessee was pursuing alternative remedy under section 154. It was also urged that there is no benefit to the assessee in filing late appeal. It was explained that the assessee filed an application under section 154 which was decided on 02.06.2015. The explanation offered by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pellate Authority (FAA). The assessee has not filed the copy of application filing before the FAA for seeking condonation of delay. 5. We have considered the submission of ld. DR for the revenue and the written submission of assessee on record. We have also deliberated on the case law relied by assessee in its written submissions. The assessment under section 143(3) was completed on 31.10.2011, the Assessing Officer while passing the assessment order made the addition/disallowance under section 14A of ₹ 1,59,930/-. No appeal was filed against the addition in the assessment order before ld CIT(A). We have noted that the assessee filed a petition/application under section 154 for rectification against the addition/disallowance under ..... X X X X Extracts X X X X X X X X Extracts X X X X
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