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2019 (12) TMI 1651

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..... AMARJIT SINGH, ACCOUNTANT MEMBER:- This assessee's appeal for A.Y. 2013-14, arises from order of the CIT(A)-8, Ahmedabad dated 14-03-2018, in proceedings under section 143(3) of the Income Tax Act, 1961; in short "the Act". 2. The solitary ground of appeal of the assessee is against the decision of ld. CIT(A) in confirming the addition of other expenses of Rs. 6,31,171/- u/s. 14A r.w.r. 8D as .....

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..... The assessing officer has not agreed with the explanation of the assessee and stated at para 7.3.5 of the assessment order that to retain the investment or to liquidate the investment the management has to make very strategic decision. The assessing officer has further stated that top management was involved in taking decision and the decision making process was very complicated which required ca .....

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..... of the investment stating that one employee cannot make investment decision. 5. We have hard rival contention and perused the material on record. The assessee has earned exempt income to the amount of Rs. 1,01,44,039/-. The assessee itself has disallowed an amount of Rs. 45,000/- incurred towards cost of employee handled the work relating to investment activities of M.F. The assessing officer ha .....

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..... mount of Rs. 45,000/- is not sufficient and appropriate looking to the size of the investment and the quantum of exempt income earned from the investment which was claimed as exempt. We are of the view that involvement of top executives and use of other business office equipment like computer etc. and office premises in respect of investment activities cannot be ruled out, therefore, we are of the .....

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