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TMI Blog2023 (12) TMI 1375X X X X Extracts X X X X X X X X Extracts X X X X ..... t : Shri J.Premanand (CIT)-Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. The sole grievance of the assessee in the captioned appeal is confirmation of certain disallowance u/s 14A. Though the assessee has raised another ground relating to disallowance of provision on security receipts while computing Book Profits, however, Ld. AR submitted that the same is tax neutral and the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... added the differential of Rs. 27.07 Corers to the income of the assessee while computing income under normal provisions as well as while computing Book Profits u/s 115JB. 4. The Ld. CIT(A) concurred with assessee's submissions that only exempt yielding investments are to be considered while computing the said disallowance. However, Ld. CIT(A) upheld the adjustment thereof u/s 115JB. Aggrieved, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vestments made by a banking concern is part of their banking business. Hence the income earned through such investments would fall under the head Profits & Gains of business. The Punjab and Haryana High Court, in the case of Pr CIT v. State Bank of Patiala [2017] 88 taxmann.com 667/393 ITR 476 (Punj. & Har.), while adverting to the CBDT Circular, concluded correctly that shares and securities held ..... X X X X Extracts X X X X X X X X Extracts X X X X
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