2020 (1) TMI 1553

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..... T(A) has recorded a finding of fact that assessee s own funds are far more than the investments in the securities and therefore no disallowance is called for in pursuant to the decision in the case of HDFC Bank (supra). Accordingly, we are inclined to uphold the order of CIT(A) on this issue by sustaining the appeal of the Revenue. - Decided against revenue. - ITA No.6329/MUM/2018 - - - Dated:- .....

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..... mpt income during the year and made suo motto disallowance u/s 14A of the Act r.w.r. 8D of Income Tax Rules at ₹ 187,14,283/-. Accordingly the AO called upon the assessee to file the working of suo motto disallowance and also show cause as to why the provisions of section 14A r.w.r 8D should not be applied. The AO came to the conclusion on the perusal of the reply of the assessee no books of .....

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..... that no disallowance under Rule 8D(2)(ii) is required to be made as assessee has more own funds than the investments which yielded exempt income during the year whereas disallowance u/s 14A r.w.r 8D(2)(iii) is confirmed. 5. After hearing both the parties and perusing the material on record, we observe that in this case the ld. CIT(A) has recorded a finding of fact that assessee s own funds are .....

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