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TMI Blog2018 (8) TMI 2024X X X X Extracts X X X X X X X X Extracts X X X X ..... PER INTURI RAMA RAO, A.M.: This appeal filed by the revenue is directed against the order dated 15.11.2016 of CIT (A)-8, Hyderabad for the A.Y. 2013-14. Revenue raised the following grounds of appeal: - "1. Ld. CIT(A) erred on both facts and law of the case. 2. Ld. CIT(A) ought to have considered that any investment which is yielding or likely to yield exempt income falls within the ambit of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the A.Y. 2013-14 was filed on 28.09.2013 declaring a total loss of Rs. 13,02,78,792/-. Against the said return of income, the assessment was completed by the Assessing Officer vide order dated 16.12.2015 passed u/s 143(3) of the Act at a total income of Rs. 2,59,44,793/-. While doing so, Assessing Officer made disallowance of Rs. 2,88,27,078/ - u/s 14A read with Rule 8D as against the exempt inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the order of the coordinate Bench of the Tribunal in the case of M/s. Renaissance Holdings & Developers Pvt Ltd., (ITA No.848/Bang/2018, dt 06.07.2018) which is relevant for the proposition that the amount of disallowance cannot exceed exempt income. He further submitted that for the purpose of computing the average value of investments for computing the amount of disallowance under Rule 8D, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... exempt income alone be considered for the purpose of computing the average value of the investments for the purpose of quantifying the amount of disallowance u/s 14A. We find that the order of the CIT(A) is in consonance with the ratios laid down by the Special Benches and therefore, we do not find any reason to interfere with the order of the CIT(A). Accordingly, grounds raised by the Revenue are ..... X X X X Extracts X X X X X X X X Extracts X X X X
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