TMI Blog2017 (8) TMI 187X X X X Extracts X X X X X X X X Extracts X X X X ..... ommissioner, it no way transpires that the appellant herein had raised any specific ground that the Assessing Officer had not arrived at the satisfaction about disallowance made by the appellant-company under Section 14A of the Act is improper, the same is being sought to be raised for the first time in the present appeal, the same would not be permissible. The findings have been arrived concurren ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Appellant Mr. N. C. Mohanty, for the Respondent. ORDER P. C. 1. The present Appeal pertains to the assessment year 2008-2009. 2. The present Appeal is filed on the following questions of law. (a) Whether on the facts and circumstances of the case the Tribunal has erred in holding that 10% of the tax free dividend income disallowed by the Appellant is not in accordance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pex Court in the case of Godrej Boyce Manufacturing Co. Ltd. Vs. Deputy Commissioner of Income Tax and another reported in [2017] 394 ITR 449 (SC). 4. The learned Senior Advocate further submits that as far as question (a) is concerned, the assessee on his own had disallowed 10% of the tax free dividend. However, the Assessing Officer had not arrived at the satisfaction and without recording ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt supports the order passed by the Tribunal. 7. Upon perusal of the grounds of appeal before the Tribunal, so also before the Commissioner, it no way transpires that the appellant herein had raised any specific ground that the Assessing Officer had not arrived at the satisfaction about disallowance made by the appellant-company under Section 14A of the Act is improper, the same is being sought ..... X X X X Extracts X X X X X X X X Extracts X X X X
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