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2018 (8) TMI 1637 - AT - Income TaxAddition on account of notional expenditure incurred to earn the exempt income by invoking Section 14A read with Rule 8D - Held that:-The Tribunal for A.Y. 2011-12 held on being dissatisfied with the assessee’s computation of disallowance, embarked on his own computation under rule 8D(2)(iii) at ₹ 5,89,98,005/-. The assessee has not disputed any part of the calculation of such disallowance. This computation of disallowance, having been made in terms of rule 8D(2)(iii), is held to have rightly made. The assessment order making disallowance of ₹ 5.89 crore u/s 14A under the normal provisions of the Act is upheld pro tanto Dispute of computation raised by assessee by filing rectification application which yet have to be decided - Held that:- We are remanding back this issue to the file of the Assessing Officer and directing the Assessing Officer to decide the rectification application filed by the assessee u/s. 154 within the reasonable time. Needless to say the assessee be given opportunity of hearing by followings principles of natural justice. Ground No. 1.3 is partly allowed for statistical purpose.
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