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2014 (12) TMI 1013 - AT - Income TaxRestriction of disallowance u/s 14A r.w Rule 8D(2)(ii) – Facts properly not appreciated by the lower authority - Held that:- Revenue rightly contended that neither the assessee nor AO is clear how much is to be disallowed for the reason that the details are not properly analyzed - none of the Authorities below have clearly sorted out the facts - even before the Tribunal , assessee could not substantiate, how the disallowance can be restricted at ₹ 68,69,801/- or at ₹ 74,06,707/- as the ground raised before the CIT(A) - the entire fact needs re-examination and hence, the matter is to be remitted back to the AO for fresh adjudication – Decided in favour of revenue.
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