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2022 (7) TMI 221 - ITAT MUMBAIRectification of mistake u/s 154 - disallowance u/s 14A - AO made disallowance under section 14A of the Act in the absence of any evidence to prove one–to–one nexus of funds received and utilized - assessee submitted that details were submitted during the course of assessment proceedings, however, the Assessing Officer failed to take note of the same while passing the assessment order - HELD THAT:- During the hearing before us, the learned A.R. filed copies of follow–up letter filed before the Assessing Officer requesting for early disposal of rectification application dated 11/06/2019, filed by the assessee. As the details filed by the assessee were not considered by the Assessing Officer while passing the assessment order and the appeal filed by the assessee before the learned CIT(A) was also dismissed only on the ground of delay, we deem it appropriate to restore this issue of disallowance under section 14A to the file of the Assessing Officer for de novo adjudication, after consideration of all the details filed by the assessee. Needless to mention that no order shall be passed without affording opportunity of being heard to the assessee. Thus, grounds raised in this appeal by the assessee are allowed for statistical purpose.
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