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2018 (7) TMI 939 - ITAT DELHIDisallowance of interest free loan advance - Held that:- The same trade advances were given by the assessee in earlier years and the commercial expediency was examined by the learned CIT(A) and ITAT in earlier years and the order of the Assessing Officer passed in the earlier years were reversed by the learned CIT(A)/ITAT for the assessment years 2010-11 and 2011-12.[2018 (4) TMI 243 - ITAT DELHI] Disallowance u/s 14A r/w rule 8D - Held that:- The grievance of the Revenue in the present case is that the learned CIT(A), without considering the satisfaction recorded in the order of Assessing Officer, has wrongly come to the conclusion that the Assessing Officer has not given cogent reason or opinion about the correctness or otherwise of the assessee’s claim. Therefore, relying upon the decision of the Hon’ble Delhi High Court in the case of Maxopp Investment Ltd. Vs. CIT (2018 (3) TMI 805 - SUPREME COURT OF INDIA) it was concluded by the Ld. CIT(A) that the Assessing has not recorded the satisfaction as required in law. However, while going through the order of the Assessing Officer, as it was clearly brought on record by the able Departmental Representative, that the Assessing Officer has duly recorded the satisfaction as required in law. Therefore, in our opinion, the finding recorded by the learned CIT(A) is without any merit and perverse, therefore, the same is required to be reversed.
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