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TMI Blog2024 (7) TMI 1484X X X X Extracts X X X X X X X X Extracts X X X X ..... uring the year. We note that the Ld. CIT(A) has failed to consider the submissions made by the assessee and dismissed the appeal in a very casual manner. Addition confirmed by the Ld. CIT(A) is not justified and cannot be sustained. In view of the fact that no disallowance is called for where there is no exempt income. As decided in R. M Commercial Pvt .Ltd. [ 2022 (2) TMI 1456 - CALCUTTA HIGH COU ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... brief are that the assessee filed return of income on 29.06.2017 disclosing the total income at Rs. 48,273/-. The case of the assessee was selected for limited scrutiny stating the reason that the assessee has returned low income in comparison to high loans/ advances/investments in shares as appearing in the balance sheet. Thereafter the statutory notices were duly issued and served upon the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income of the assessee. 4. In the appellate proceedings, the Ld. CIT(A) dismissed the appeal of the assessee by observing that the assessee did not file any response to the notice issued by the AO. During the appellate proceedings the assessee did not file any details in support of its claim and contentions and finally sustained the addition of Rs. 28,93,440/- which was calculated by the Ld. CIT( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... into account the written submission filed by the assessee by stating that the assessee has not filed any details/finding in respect of grounds of appeal whereas the facts on record suggests to the contrary. We note that the assessee has duly uploaded detailed reply on 08.04.2019 online the acknowledgment whereof is available at page no. 6 of PB. We note that in para 4 of the said reply ( page 7 of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the fact that no disallowance is called for where there is no exempt income. The case of the assessee finds support from the decision of Hon ble Calcutta High Court in the case of PCIT vs. R. M Commercial Pvt .Ltd. [2022] 138 taxmann.com 21 (Calcutta) wherein it has been held that no disallowance u/s 14A is called for as the assessee has not received any exempt income during the year. Accordingl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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