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2021 (4) TMI 462 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - direct and administrative expenses - HELD THAT:- We notice that as followed the tribunal’s order in assessee’s case itself for A.Y 2013- 14 [2018 (8) TMI 2024 - ITAT HYDERABAD] that only exempt income yielding investments deserve to be considered for the purpose of Rule 8D disallowance computation. The Revenue is equally fair in its substantive ground in not pinpointing any distinction on facts or law in these twin assessment years. We thus adopt judicial consistency to affirm CIT (A)’s impugned directions. Revenue’s formal appeal rising this solitary substantive grievance fails therefore. Addition u/sec 115JB MAT issue qua sec 14A disallowance - HELD THAT:- This tribunal’s special bench in VIREET INVESTMENT (P.) LTD. [2017 (6) TMI 1124 - ITAT DELHI] has decided the issue to assessee’s favour. Thus Rule 27 petition is partly allowed to this limited extent.
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