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2017 (2) TMI 626 - ITAT MUMBAI

2017 (2) TMI 626 - ITAT MUMBAI - TMI - Disallowance u/s 14A computation - Held that:- Revenue has invoked Rule 8D of Income-tax Rules, 1962 for making disallowance u/s 14A of the Act in a stereo typed manner without having regard to the accounts of the assessee and without satisfying the mandate of Section 14A(2) of the Act before making disallowance u/r 8D(2)(iii) of Income-tax Rules, 1962 read with Section 14A of the Act which in our considered view cannot be sustained in the instant appeal ke .....

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of the Act and also no attempt was made by the AO to dislodge the claim of the assessee in bringing forth and working disallowance u/s 14A of the Act having regard to the accounts of the assessee. In our considered view, the disallowance made by the A.O. in the instant appeal u/s 14A of the Act r.w.r. 8D(2)(iii) of Income-tax Rules, 1962 cannot be sustained and the disallowance of the expenses is to be made keeping in view expenses debited to the Profit and Loss Account (including , inter-alia, .....

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in accordance with law before de-novo determination of disallowance of expenses u/s 14A of the Act on merits. - I .T.A. No.1306/Mum/2015, I .T.A. No.1540/Mum/2015 - Dated:- 8-2-2017 - SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER For The Assessee : Shri Rushabh Mehta For The Revenue : Dr. Santosh Mankaskar,DR ORDER PER Bench These are bunch of four appeals pertaining to two different assessee s consisting of cross appeals by the assessee as well Revenue. Out of thes .....

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before learned CIT(A) has arisen out of two different assessment orders both dated 09-01-2014 passed by learned ACIT, Central Circle-13, Mumbai(hereinafter called the AO ) u/s 143(3) of the Income-tax Act,1961(hereinafter called the Act ). The issues involved in these appeals are common; the same have been heard together and are being disposed of by this single consolidated order for the sake of convenience. First we shall take up Revenue s appeal in ITA No. 1540/Mum/2015 for assessment year 20 .....

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erefore, the expenditure incurred by it should have been capitalized under the head 'Capital work-inprogress' as against revenue expenditure claimed by the assessee? (ii) The Appellant craves leave to add, to amend and /or to alter any of the grounds of appeal, if need be. (iii) The Appellant, therefore, prays that on the grounds stated above, the order of the CIT(A)-37 , Mumbai be set aside and that of the Assessing Officer restored." 3. The brief facts of the case are that the ass .....

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nce Mall Developers Co. Pvt. Ltd. (ii) Hagwood Commercial Developers P. Ltd. (iii) Empire Mall Pvt. Ltd. The Revenue invoked Section 153C of the Act after satisfaction note has been recorded against the assessee company, as the documents belonging to the assessee company had been seized in the search action in the case of M/s Provogue (India) Limited. Notices dated 13-08-2013 were issued to the assessee u/s 153A r.w.s. 153C of the Act . The assessee filed return of income on 22-08-2013 declaring .....

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disallowed since there was no business activity and there was no business income and the project is still under progress. The assessee in reply submitted before the AO , submissions dated 18.11.2013 wherein it was contended as under:- With reference to your query regarding allowability of expenses claimed by debiting to Profit & Loss Account and not to capitalise it as project cost, we wish to state that expenses which are directly attributable to the project undertaken are classified under .....

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ce expenses being in nature of period cost are debited to profit and loss account. It will be appreciated that such a treatment is supported by two basic principles of determination of business Lincome both for the purposes of accounting as well as income tax. c) The first principle is regarding treating of project expenses as Capital Work-in-Progress. It is pertinent to note that the assessee is in business of development and construction of malls and residential projects. Your Honour would app .....

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as revenue expenditure, it will be appreciated that they are in nature of administrative expenses. Also some of the expenses like auditors remuneration are incidental expenses for the functioning of the assessee company. They are neither expenses incurred in relation to the projects undertaken nor they can be recouped. As such they have to be debited to profit and loss account and are allowable in the year in which they are incurred. f) The assessee further submits that keeping in view the busi .....

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ted to the contract; and (iii) Such other costs as are specifically chargeable to the customer under the terms of the contract. h) Further, AS-7 also provides that Costs that cannot be attributed to contract activity or cannot be allocated to a contract are excluded from the costs of a construction contract. Such costs include: (i) General administration costs for which re-imbursement is not specified in the contract; (ii) Selling costs; (iii) Research & development costs for which reimburse .....

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n-progress and debiting the above expenses in the Profit & Loss A/c as revenue expenditure is correct and is in line with the AS-7. k) Moreover, we also wish to submit that the valuation of work in progress is governed by AS-2 "valuation of Inventories". As per AS-2 on valuation of Inventories issued by the ICAI, cost of inventories comprises of all cost of production, cost of conversion and other cost incurred in bringing the inventories to their present location and condition. It .....

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e judicial pronouncement given by the Hon'ble Guwahati High Court in the case of MKB (Asia) (P.) Ltd. v. CIT , whereby it held as under:- "The income tax authority has no option/jurisdiction to meddle in the matter either by directing the assessee to maintain its accounts in a particular manner or adopt a different method for valuing the work-in-progress. An assessee has the option / liberty to adopt any recognized method of accounting for its business and the income should be computed .....

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n-Progress has been valued correctly and the revenue expenses have been rightly claimed in the Profit & Loss account during the year under consideration. Without prejudice to the above, if any such expenditure, being revenue in nature, is disallowed on any ground, the said expenditure as disallowed has to be added to the cost and accordingly the cost of the project will be increased to that extent. The A.O. rejected the contentions of the assessee by holding as under:- (i) The assessee has c .....

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period are classified as project development expenditure pending capitalization included in capital work-in-progress and will be apportioned to the assets on the completion of the project. " (iii) In clause- II9 appended to Schedule-l0 of the annual accounts for the F.Y. 2009-10 and in clause B11 appended to Schedule 11 of the annual accounts for the F.Y. 2010-11, it is mentioned as under: "The company is planning a retail centric mixed used development project at Nagpur. The expendit .....

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uch expenditure would be capitalized upon the commencement of commercial operations of the Project. ii. Incidental expenditure during construction period pending allocation included in capital work in progress represents expenditure incurred in connection with the project which is intended to be capitalized to the project. Expenditure not attributable to project are charged to revenue account. iii. Common expenditure is allocated to project cost on certain basis as considered appropriate by mana .....

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the impugned mall on its completion, under the head 'Income from House Property' or under the head 'Profit & Gains from Business or Profession', the mall will remain a capital asset and not its stock-in-trade. The other details filed during the course of assessment proceedings on 19.09.2013 also confirms that the assessee is neither a builder & developer engaged in developing real estate for sale to consumers nor a contractor engaged in construction activity. Therefore, .....

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r to setting up of the business and commencement of the business falls under the category of pre-operative expenses. The proviso to section 3 clearly specify the "previous year" as under:- "Provided that, in the case of a business or profession newly set up, or a source of income newly coming into existence) in the said financial year) the previous year shall be the period beginning with the date of setting up of the business or profession or, as the case may be, the date on which .....

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ment & business promotion, etc. in P&L a/c and further claimed the same as loss under the head profits & gains of business. (vii) Further, the claim of the assessee that the valuation of inventories is governed by Accounting Standards (AS)-2 is not relevant as the assessee has not shown the construction as stock-in-trade. Therefore, the decision of the Hon'ble Gauhati High Court in the case of MKB (Asia) Pvt. Ltd. Vs. CIT (supra) quoted by the assessee is also not applicable to t .....

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essee has not been earning any business income in the year and on other side, it is claiming expenses which are factually in connection with the construction activity undertaken by the assessee. In view of this, the assessee would be eligible to claim the expenditure only when any income is offered out of the business and upto that stage, no claim of expense shall be given. (x] Further, reliance is placed on the following decisions: (a) Kingfisher Training & Aviation Services Ltd. vs. ACIT ( .....

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Act. 4. Aggrieved by the assessment order dated 09-01-2014 passed by the A.O. u/s 143(3) of the Act, the assessee carried the matter before the ld. CIT(A) by filing first appeal. The ld. CIT(A) after considering the facts of the case allowed the appeal of the assessee vide appellate orders dated 29-12-2014 by holding as under:- 5.6 Ground of appeal no. 3 and 6(b) is in respect of disallowance of expenses of ₹ 10,04,082/-. The appellant argued that it was in the business of development and .....

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xpenses are incurred year after year to create awareness in respect of prospective customers about the project. These are neither deferred revenue expenditure nor capital in nature since there are incurred repetitively to promote the project. As regards the view of the A.O. that the appellant Company had not set up and commenced its business and the nature of work performed was purchase of land . It was not necessary that all categories of business activities must support simultaneously . Unless .....

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l is the date when the company went into or started one or the other of its component activities. In the present case, the appellant set up its business in AY 2008-09. Reliance was placed on the decision of Bombay High Court in the case of M/s Western India Vegetable Products (26 ITR 151) wherein it was held that the expenses should be allowed in the year in which business is set up, and a distinction was drawn between business being setup and commencement of business. It is not necessary that i .....

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directing the assessee to maintain its accounts in the particular manner or adopt a different method for valuing the work-in-progress. An assessee has the option/liberty to adopt any recognized method of accounting for its business and the income should be computed in. accordance with such regularly maintained accounting system. Thus, the Tribunal was not right in not accepting the valuation of closing work-in-progress in accordance with the Accounting Standard 7." 5.8. It is seen that lan .....

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on of the accounting standards. Even in the Guidance Note on Accounting for Real Estate Transactions (Revised) 2012, the terms Project Costs has been defined. It is categorically mentioned in Para 2.4. that: "2.4. The following cost should not be considered part of construction cost and development costs if they are material: (a) General administration costs (b) Selling costs (c) Research and development costs (d) Depreciation of idle plant and equipment (e) Cost unconsumed or uninstalled m .....

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it should be a method recognized under section 145 of the Act and it should be used consistently. The choice of the method has been left to the assessee. In this context, the following observation of the Hon'ble Gujarat High Court, made while rendering its decision in the case of CIT v. Advanced Construction Co. (P) Ltd. (275 ITR 30), would be contextually important. "The provision therefore specifically provides that the choice of method of accounting lies with the assessee, the only .....

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ing standards. The disallowance made by assessing officer is therefore deleted. Ground of appeal no 3 and 6(b) are allowed. 5. Aggrieved by the appellate order dated 29-12-2014 passed by the ld. CIT(A), the Revenue is in appeal before the tribunal. 6. The ld. D.R. submitted that the assessee has not set up any business during the impugned assessment year as the malls were under construction and no business was set up. The assessee is not a builder, the assessee set up a mall as a capital asset. .....

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approvals were obtained by the assessee for construction of mall and residential complex. He submitted that the assessee is bound to follow the Accounting Standards notified in accordance with section 211(3C) of The Companies Act,1956 as were applicable during the impugned assessment year. The assessee is following the Accounting Standard consistently in accordance with law and it could not be said that by following the said accounting standards so mandatorily required to be followed by the ass .....

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of land, earth excavation and other land development activities , etc. Also, land dividation and barbed wire fencing were carried out. A.Y.2010-11 The No Objection Certificate (NOC) has been received from the Tehsildar s Office. A.Y.2011-12 Construction of the boundary wall surrounding the plot of construction and other allied land development activities. AY 2012-13 Construction of Water Bound Macadem road, leveling of site and laying hard murum. Further, height clearance was also received from .....

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rposes of this Act, "previous year" means the financial year immediately preceding the assessment year : Provided that, in the case of a business or profession newly set up, or a source of income newly coming into existence, in the said financial year, the previous year shall be the period beginning with the date of setting up of the business or profession or, as the case may be, the date on which the source of income newly comes into existence and ending with the said financial year . .....

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(3C) of the Companies Act,1956 which the assessee company is mandatorily required to follow. It was submitted that now the project is converted into Mall and residential project . He submitted that the assessee has received advances from various parties and the mall/residential complex is still under construction. The civil engineer certificate is placed on record at page 38/paper book which was also placed before authorities below The ld. Counsel relied on the following judicial decisions and s .....

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rnment to construct Mall and residential project at Nagpur. He also drew our attention to paper book page No. 11 whereby it is certified by the Auditors that the applicable accounting standards referred to in Section 211(3C) of the Companies Act, 1956 were followed regularly by the assessee. It was submitted that the assessee was following mandatory accounting standards AS-7 and AS-2 issued by ICAI and it could not be said that by following said accounting standards , the profit of the assessee .....

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ecord. We have observed that the assessee is a private limited company engaged in constructing a mall and residential complex at Nagpur. The assessee purchased land and obtained various government approvals from time to time in preceding assessment years . The construction of the mall and residential complex is in progress during the previous year relevant to the impugned assessment year. The activity chart as detailed by the assessee before the authorities below as under could not be controvert .....

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evelopment activities. AY 2012-13 Construction of Water Bound Macadem road, leveling of site and laying hard murum. Further, height clearance was also received from the Airports Authority of India(AAI) and Bharat Sanchar Nigam Lid(BSNL) We have observed that activity towards construction of mall and residential complex was started way back in assessment year 2008-09 onwards as emerging from the records. We find that the assessee is consistently following AS-2 & AS-7 issued by ICAI which are .....

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d the general overhead expenses being indirect expenses incurred in the P&L account in compliance with AS-2 & AS-7 which is mandatory as per ICAI and notified by Central Government as per Section 211(3C) of the Companies Act, 1956 wherein the Companies are statutorily required to follow the same. It could not be pointed out by learned DR that how by following the afore-stated Accounting Standards which are mandatory accounting standards, profits of the assessee could not be computed corr .....

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e case may be, the date on which the source of income newly comes into existence and ending with the said financial year and thus it is not necessary the business had actually commenced for claiming the expenses but the relevant is the setting up of the business which in our considered view in the instant appeal business was set-up when the assessee took steps to purchase land and obtained necessary approvals for setting up of Mall and Residential complex at Nagpur. In our considered view, there .....

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s appeal in ITA No. 1306/Mum/2015 for assessment year 2012-13. 10. The Brief facts of the case are that on perusal of the P&L account, it was observed by the A.O. that the assessee has investment in shares and mutual funds amounting to ₹ 56,00,10,000/- income from which is exempt from tax u/s. 10 of the Act. The assessee was asked to furnish detail of the expenses disallowed u/s 14A of the Act out of the expenses debited under various heads in P&L account in relation to earning of .....

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which exempt income is earned. Further, it may be noted that the investment decisions are solely taken care of by the portfolio manager - "Trust Capital Services Pvt. Ltd. . Other Expenses claimed of ₹ 1,01,12,014/- is bifurcated as below: S No. Particulars Amount Status a) Professional fees 7,50,690 Out of this ₹ 4,09,690/- towards portfolio management fees of Trust Capital Services P.Ltd. is already disallowed. b) Rates & Taxes 3,201 c) Advertisement and Business Promotio .....

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to ₹ 4,09,690/- incurred in relation to the portfolio management fees (broker) who takes care of the investment decisions. For the purpose of said disallowance, the assessee has considered the common expenses which may be said to have attributable towards taxable income as well as exempt income. Accordingly, the working of the disallowance is as under:- Pareticulars of common expenses Amount Rates & Taxes 3,201 Travelling expenses 2,52,878 Communication expenses 7,689 Printing & St .....

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attributable to the taxable business income earned and hence, shall not be considered for the purpose of 14A disallowance. In this regard, we wish to state that the party-wise details of the advertisement & business promotion expenses incurred in the year under consideration has already been submitted in our earlier submission. c) Your Honour may also note that no interest expenses are claimed by the assessee. In view of the above submission, we request Your Honour not to make any disallowan .....

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italized the same under the head capital work-in-progress . The expenses incurred on salary and wages( ₹ 47,72,015) , bonus (Rs. 71,076) , Boarding and Lodging (Rs.16,701) , travelling (Rs. 98,240) etc. have been transferred to capital work-in-progress. The AO observed that the assessee incurred expenses on construction of mall and capitalized the same under the head capital work-in-progress. The AO observed that some portion of expenses incurred by the assessee on salary, administrative e .....

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but the said expenses had been claimed u/s 57 of the Act under the head-income from other sources. The AO observed that he is satisfied that the disallowance of expenses of ₹ 2,00,000/- by the assessee u/s 14A of the Act in relation to income which does not form part of total income is not correct having regards to the accounts of the assessee, dividend income earned of ₹ 14,06,951/- and huge investments in shares. The AO invoked the provisions of Section 14A of the Act read with Rul .....

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e sheet of the assessee on the first and last day of the previous year as per Rule 8D((2)(iii) {[(68,69,81,000+56,00,10,000)/2] * 0.5% } 31,17,478 Total Disallowance u/s. 14A r.w.r. 8D 31,17,478 Less : Expenses disallowed u/s14A 2,00,000 Net Disallowance u/s. 14A r.w.r.8D 29,17,478 Since, the AO disallowed whole of expenditure debited to Profit and Loss account on the grounds that no business had been set up by the assessee, no separate disallowance was made on account of Section 14A of the Act .....

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ied the matter before the ld. CIT(A) in first appeal, who rejected the contentions of the assessee. However , learned CIT(A) accepted the contentions of the assessee that the disallowance of expenses u/s 14A of the Act is to restricted out of the expenses debited to Profit and Loss Account and the same cannot be extended to the direct cost incurred towards the construction of Mall which is capitalized to capital workin- progress account as the said expenses are direct expenses towards the projec .....

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for the assessee that the A.O. has disallowed the expenses u/s 14A of the Act by invoking Rule 8D of Income-tax Rules, 1962. The AO has also included the direct expenses incurred for construction of mall and residential complex which were debited by the assessee to the capital work-in-progress against which learned CIT(A) has given relief vide appellate orders dated 29-12-2104 . Rule 8D of Income-tax Rules, 1962 was invoked by the A.O. for making disallowance u/s 14A of the Act. The disallowanc .....

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f such expenses , the assessee worked out disallowance of ₹ 76,024/- u/s 14A of the Act having regard to the accounts of the assessee against which voluntary disallowance of ₹ 2,00,000/- were made. The details are enumerated in the orders of authorities below and it was submitted that Advertisement and business promotion expenses of ₹ 89,61,150/- were not included for the purpose of disallowance u/s 14A of the Act as the same were directly attributable to the taxable business i .....

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in the case of Power Grid Corporation of India Limited v. DCIT in ITA No. 2397 an 2398/Del/2014 vide orders dated 06.10.2016. 14. The ld. D.R. relied on the order of ld. CIT(A). 15. We have considered the rival contentions and also perused the material available on record including the case laws. We have observed that the assessee is a Private Limited Company which is engaged in constructing a mall and residential complex at Nagpur. The assessee has set up business of constructing mall and resid .....

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truction of mall and residential complex by transferring the said expenses to capital work-in-progress which were also considered by the AO for disallowance u/s 14A of the Act by invoking Rule 8D(2)(iii) of the Incometax Rules, 1962 against which learned CIT(A) gave relief to the assessee and the Revenue is not in appeal against the relief granted by learned CIT(A), thus, the expenses which were capitalized being direct expenses debited to capital work-in-progress being incurred for construction .....

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rtisement and Business Promotion expenses of ₹ 89,61,150/- were directly attributable to the earning of taxable business income earned and hence the same shall not be considered for the purposes of disallowance under section 14A of the Act . The Revenue could not point out any discrepancy in the said contention of the assessee. The assessee has also investment in non-current investment of ₹ 56 crores as at 31-03-2012 which is same as in the preceding year as at 31-03-2011. The assess .....

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t as charged by portfolio managers and chargeability by portfolio managers of PMS fees be apportioned accordingly for disallowance u/s 14A of the Act between current and non-current investment as also keeping in view investment in taxable as well tax-free instruments , while the assessee has deducted the said PMS expenses u/s 57 of the Act. The Revenue has invoked Rule 8D of Income-tax Rules, 1962 for making disallowance u/s 14A of the Act in a stereo typed manner without having regard to the ac .....

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the assessee. The AO did not made any attempt to work out disallowance of expenses incurred in relation to earning of income which does not form part of total income having regards to the accounts of the assessee in accordance with mandate of Section 14A(2) of the Act and also no attempt was made by the AO to dislodge the claim of the assessee in bringing forth and working disallowance u/s 14A of the Act having regard to the accounts of the assessee. In our considered view, the disallowance made .....

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