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TMI Blog2022 (8) TMI 1191X X X X Extracts X X X X X X X X Extracts X X X X ..... thorities. In view of this we do not find any infirmity in the order of the learned that lower authorities in confirming the addition u/s 68 - ground no. 1 of the appeal of the assessee is dismissed. Disallowance u/s 14A - CIT(A) restricted the addition/disallowance only with respect to the administrative expenditure at the rate of 0.5% of the average value of investment whereas the AO made the disallowance of ₹ 45,1927 - HELD THAT:- As the disallowance confirmed by the learned CIT(A) is ₹ 55,511/ . We do not find any infirmity in the order of the learned CIT(A). Accordingly, his order is confirmed. Ground number 2 is dismissed. - ITA No. 5719/Mum/2016 - - - Dated:- 26-8-2022 - Shri Prashant Maharishi, AM And Shri Sande ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in grey fabrics. During the year the assessee has received sale application money from nine different parties amounting to ₹ 495 lakhs out of which ₹ 450 lakhs was received during the year at the rate of ₹ 200 per share. The assessee before the assessing officer furnished the return of income, the audited accounts as well as the bank statement of investors of only 25 lakhs. The AO found that the share value of the assessee is not in accordance with the value of the shares that is only ₹ 82 per share, the gross profit ratio of the assessee is meager and assessee has not provided any basis for figure on the basis of which valuation of shares was arrived at. AO was also concerned that for the year under consideration as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onate to their earnings on verification of the financial statement of the investors. v. Meager profits, meager resources in the form of share capital et cetera shows of creditworthiness of the investors. vi. The investment is made by investor company is in same set of common private limited companies run by common persons. vii. Only identity of the investors is established, creditworthiness is questionable and genuineness of the transaction is not established. 05. With respect to the disallowance under Section 14 A of the Act, he directed the learned Assessing Officer to restrict the disallowance as per Rule 8D only with respect to 0.5% of the investments. The reason being that that the funds for investment are out of non-intere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is we do not find any infirmity in the order of the learned that lower authorities in confirming the addition of ₹ 450 lakhs under Section 68 of the Act. Accordingly ground no. 1 of the appeal of the assessee is dismissed. 09. The ground no. 2 is with respect to the disallowance under Section 14 A of the income tax Act. During the year the assessee has received exempt income of ₹ 303,250/ . The learned CIT(A) restricted the addition/disallowance only with respect to the administrative expenditure at the rate of 0.5% of the average value of investment whereas the AO made the disallowance of ₹ 45,1927 the disallowance confirmed by the learned CIT(A) is ₹ 55,511/ . We do not find any infirmity in the order of the lea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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