2014 (3) TMI 1208

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..... r - CIT-A has held that the claim of deduction under sec.80JJAA in respect of regular workmen recruited in the earlier years and pertaining to relevant assessment year can be allowed only if the claim has been upheld in the assessment year in which the recruitment of such workmen was made - HELD THAT:- As rightly held by the Commissioner of Income tax (Appeals), the above dictum of statute cannot .....

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..... apply for the assessment year 2006-07. Proportionate disallowance made by the Assessing Officer of the loan interest is not on any verifiable basis. It is a blunt disallowance. It cannot be upheld. Therefore, the said disallowance is deleted. This ground is decided in favour of the assessee. - ITA Nos. 1357 & 1358/Mds/2010 - - - Dated:- 17-3-2014 - DR. O.K. NARAYANAN, VICE-PRESIDENT AND SHRI S .....

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..... ls) has erred in confirming the disallowance of claim made by the assessee under sec.80JJAA of the Act. For the assessment year 2006-07, it is the case of the assessee that the Commissioner of Income-tax (Appeals) has not only erred in confirming the disallowance made by the assessing authority but also grievously erred in enhancing the disallowance. 4. Another ground raised only for the assess .....

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..... respect of whom the claim was denied on the basis that they have not completed 300 days in the preceding year should be allowed deduction in subsequent year, wherein they have completed 300 days, does not hold force since the section clearly specifies that the additional wages is to be determined only for new regular workmen employed by the assessee in the previous year . As rightly held by the .....

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..... essee. 7. Next, we will consider the ground raised for the assessment year 2006-07 in respect of disallowance made under sec.14A read with Rule 8D. Sec.14A as well as Rule 8D do not apply for the assessment year 2006-07. Proportionate disallowance made by the Assessing Officer of the loan interest is not on any verifiable basis. It is a blunt disallowance. It cannot be upheld. Therefore, the sa .....

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