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2019 (3) TMI 11 - AT - Income TaxDisallowance u/s 14A read with Rule 8D (ii) - satisfaction about the correctness of the claim of the assessee - HELD THAT:- In this case AO without recording his dissatisfaction / reasons as to his satisfaction about the correctness of the claim of the assessee mechanically proceeded to invoke the provisions contained u/s 14A with Rule 8D which is not permissible under law. CIT(A) has deleted the addition on the basis of facts that expenditures debited to P & L Account by the assessee have been suo moto added back by the assessee in the computation of income. So, we find no scope to interfere into the findings returned by CIT(A). Income from other sources - forfeiture of earnest money received during the negotiation of a capital assets - Insertion of new subsection (IX) in Section 56(2) w.e.f. 01.04.2015 is prospective - sale proceeds forfeited to be deducted from the cost acquisition of the property in question u/s 51 - HELD THAT:- Since in A.Y. 10-11 there was no provision under the Act for treating the forfeiture of earnest money received during the negotiation of a capital assets as income from other sources, the CIT(A) has rightly deleted the addition. The issue in controversy is also covered by decision rendered by Co-ordinate bench of Tribunal in case of Vijay Singh [2014 (12) TMI 599 - ITAT DELHI]. - Decided against the revenue.
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