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TMI Blog2021 (1) TMI 734X X X X Extracts X X X X X X X X Extracts X X X X ..... on the first day and the last day of the year under consideration - HELD THAT:- We note that the AO has mentioned that the assessee has suo motu disallowed as disallowance u/s. 14A of the Act. Although, AR has argued that no such suo motu disallowance was made by the assessee in its computation of income, for want of evidences we cannot look into the issue at this juncture. Considering the smalln ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ge is the upholding of the disallowance of ₹ 8,28,036/- u/s. 14A of the Income tax Act, 1961 (hereinafter called 'the Act'). 2. The brief facts of the case are that the assessee company is a 100% owned subsidiary company of M/s. Maruti Suzuki India Limited (formerly known as Maruti Udyog Limited). It has tied up with New India Assurance Company Ltd. as its Licensed Corporate Insur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s incorrect because there was no opening and closing balance of investments in the assessee's books on the first day and the last day of the year under consideration. It was submitted that if the average value of assets was nil, the disallowance would also be nil. It was also submitted that the Assessing Officer has made an incorrect assertion in the assessment order that the assessee had made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... zed Representative has argued that no such suo motu disallowance was made by the assessee in its computation of income, for want of evidences we cannot look into the issue at this juncture. Considering the smallness of the amount and also the alternate plea of the Ld. Authorized Representative on overall facts of the case, we direct that the disallowance be restricted to ₹ 67,853/- i.e. the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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