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2022 (9) TMI 1466 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - suo moto addition made by assessee - sufficiency of own funds - HELD THAT:- DR could not substantiate argument as to why inspite of a suo moto disallowance being made by the Assessee without justifying anything to differ, the AO made a disallowance while the interest expenditure was incurred to earn taxable income only. At the same time the Assessee’s own fund as on 31.03.2015 were Rs. 145173.31 and investment of Rs. 1957.39 lacs. No intervention required in the findings of the ld CIT(A) which based on correct interpretation and reliance of law. The ground is No. 1 decided against the revenue. Disallowance of prior period expenses - CIT-A deleted the addition - HELD THAT:- DR could not submit anything to show that how there is any difference of facts or law in regard to the issue when the same has been decided in Assessee’s own case by the order of Tribunal in preceding years. AO made addition relying on the orders for preceding years and the ld CIT(A) had deleted the addition relying on the decision of the tribunal in Assessee’s own case for Assessment Year 2009-10. Thus, there is no substance in the ground. The same is decided against the revenue.
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