TMI Blog2015 (1) TMI 1297X X X X Extracts X X X X X X X X Extracts X X X X ..... f the view that the fresh contention put forth by the Ld A.R also needs to be examined at the end of the assessing officer. Accordingly, we set aside the order of ld. CIT(A) on this issue and restore the matter to the file of the AO with a direction to examine the claim of the assessee afresh and take appropriate decision in accordance with law. Appeal filed by the assessee is allowed for stati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce made u/s 14A of the Act. 4. We have heard the parties and perused the record. The impugned disallowance made by the AO relates to disallowance of 0.05% of the administrative expenses as per the provisions of Rule 8D r.w. section 14A of the Act. While filing the return of income, the assessee did not make any disallowance u/s 14A of the Act even though it had received ₹ 8.32 crores ad d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are all passive investments made with the strategic business purpose of holding controlling interest. Accordingly he submitted that the impugned investments have not been made for the purposes of earning dividend income. The ld. counsel submitted that out of the investment of ₹ 20.01 crores, the investment in mutual funds units was only ₹ 58 lakhs and remaining investment have been ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. We also notice that the contention of the assessee is supported by the two Tribunal decisions referred (supra). The claim of the assessee is that the companies in which the investment have been made are subsidiary and Group companies. However, we are of the view that the said claim requires verification at the end of the AO. Further, we are of the view that the fresh contention put forth by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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