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2019 (6) TMI 785 - AT - Income TaxAddition u/s 14A - assessee made suo-moto disallowance - HELD THAT:- AO while making the disallowance has given a finding that investment in shares and securities have been made out of borrowed funds. It is the submission of the assessee that no borrowed funds have been utilized for making the investment and no new investments have been made during the year. Considering the totality of the facts of the case and in the interest of justice we deem it proper to restore the issue to the files of the Assessing Officer with a direction to verify the records properly and decide the issue as per fact and law after giving a reasonable opportunity of being heard to the assessee.- Decided in favour of assessee for statistical purpose.
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