9911796707
TMI Blog2022 (7) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... only grievance of the assessee in the present appeal is against the dismissal of its appeal by the learned CIT(A) as non-maintainable. 3. The brief facts of the case pertaining to the issue, as emanating from the record, are: The assessee is a manufacturer of dyes and chemicals and also earns income from dealing in investments and shares. For the year under consideration, the assessee e-filed his return of income on 24/09/2013, declaring total income of Rs.2,10,08,050. The Assessing Officer, vide order dated 28/01/2016, passed under section 143(3) of the Act, inter-alia, disallowed expenditure of Rs.1,58,362, under section 14A r/w rule 8D of the Income Tax Rules, 1962 ("the Rules") in relation to the income which does not form part of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the appellant. It is noticed that the same is merely a copy of the rectification application of the assessee dated 14.014.2020 on which the A.O. has merely endorsed in his handwriting on 24.02.2020 in the space available at the bottom right hand comer that the rectification application is rejected as it is a matter of appeal. It is noticed that there is no separate order passed by the A.O. u/s 154 of the Act on 24.02.2020 along with a demand notice bearing the said date. 6. Further is that no computer generated Document Identification Number (DIN) has been quoted in the body of the said document purported to be a rectification order. The CBDT Circular 19 of 2210 de 14.08.2010 issueded in pursuance of provisions of section 119 of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owance made under section 14A of the Act. The learned A.R. further submitted that the learned CIT(A) dismissed the appeal of the assessee as not maintainable on technical grounds. 7. On the other hand, the learned Departmental Representative by vehemently relying upon the impugned order submitted that the disallowance under section 14A of the Act is not covered within the ambit of section 154 of the Act. 8. We have considered the rival submissions and perused the material available on record. The assessee being aggrieved with the incorrect computation of disallowance under section 14A of the Act sought rectification of the assessment order. In the rectification application, the assessee submitted as under: "While going through the order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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