2023 (1) TMI 1395

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..... wance made by AO - HELD THAT:- ITAT by the impugned order has correctly held that the assessee has made a total disallowance of Rs. 30.23 crores, which is more than the dividend of Rs. 2.05 crores. Since, assessee has voluntarily made disallowance, it would meet the requirement of Section 14A of the Act and further disallowance made by the AO and confirmed by the CIT(A) is not warranted as the dis .....

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..... will meet the requirements as set out in a Section 14A of the Act even though the conditions for invoking were satisfied in the case of the assessee ? 2) Whether on the facts and in the circumstances of the case and in law, the Tribunal was right in not distinguishing the law applicable for investment in stock in trade as laid out by the Supreme Court in the case of M/s Maxopp Investments Ltd 402 .....

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..... been dismissed. 4. The ITAT by the impugned order has held that the assessee has made a total disallowance of Rs. 30.23 crores, which is more than the dividend of Rs. 2.05 crores. Since, assessee has voluntarily made disallowance, it would meet the requirement of Section 14A of the Act and further disallowance made by the AO and confirmed by the CIT(A) is not warranted. 5. Shri. Aravind submitted .....

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