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2021 (2) TMI 680 - HC - Income TaxRevision u/s 263 - order passed by the Assessing Officer u/s 143(3) rws 147 was erroneous in so far as it is prejudicial to the interest of the Revenue - Disallowance of expenditure on account of the accumulation under Section 11(1)(a) in respect of the car purchased in the name of the trustee - appellate tribunal directed the Assessing Officer to restrict the disallowance to the extent of ₹ 9,56,175=00 and not disallow the entire accumulation as held by the CIT(E) - HELD THAT:- As decided by tribunal we consider that in the case of the assessee on violation of Section 13(1) (c)(ii)/13(2) r.w.s. 13(3), the disallowance u/s. 11 is limited only to the amount which the assessee trust has diverted for purchase of a car in the name of trust, i.e. ₹ 9,56,175/-. Considering the above, we direct the Assessing Officer to restrict the disallowance to the extent of ₹ 9,56,175/- and not to disallow the entire accumulation as held by the Ld. CIT(A). We are of the view that no error, not to speak of any error of law, could be said to have been committed by the Tribunal in passing the impugned order.
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