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TMI Blog2020 (8) TMI 885X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowance to only ₹ 39,70,832/-. Tribunal considered the factual position and earlier order passed by the Tribunal in the assesse's own case and held that the Revenue has not been able to point out any error in restricting the disallowance under Section 14(A) to ₹ 39,70,832/- being 0.5% of the average value of the investment. Thus, we find that the Tribunal has given a finding as to why it does not find any ground to interfere with the order passed by the CIT(A). In our considered view, the entire issue involved is fully factual and reasonableness of the expenditure incurred has been computed by the CIT(A) and confirmed by the Tribunal after considering the merits of the matter. - T.C.A. No. 250 of 2020 - - - Dated:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n, learned counsel for the respondent/assessee. 3. The short issue which falls for consideration is as to whether any perversity in the order passed by the Tribunal as pointed out by Mr.M.Swaminathan, learned senior standing counsel. The assessee is a Government of Tamil Nadu Undertaking filed its Return of Income for the relevant Assessment Year 2013-14 on 23.09.2013 admitting an income of ₹ 104,45,91,740/-. The case was selected for scrutiny and notice under Sections 143(2) and 142(1) was issued to the assessee. 4. In this appeal, we are concerned about the disallowance under Section 14 (A) read with Rule 8D of the Income Tax Rules. The Revenue is before us contenting that the Commissioner of Income Tax (Appeals)-11, Chennai [ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isallowance under Section 14(A) at R.39,70,832/-. This is a statement of fact. The second facet of the finding is with regard to the Revenue's contention that CIT(A) erred in restricting the disallowance to only ₹ 39,70,832/-. The Tribunal considered the factual position and earlier order passed by the Tribunal in the assesse's own case and held that the Revenue has not been able to point out any error in restricting the disallowance under Section 14(A) to ₹ 39,70,832/- being 0.5% of the average value of the investment. 8. Thus, we find that the Tribunal has given a finding as to why it does not find any ground to interfere with the order passed by the CIT(A). In our considered view, the entire issue involved is fully ..... X X X X Extracts X X X X X X X X Extracts X X X X
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