TMI Blog2018 (4) TMI 521X X X X Extracts X X X X X X X X Extracts X X X X ..... kisha Engineering India Ltd.(2014 (12) TMI 482 - DELHI HIGH COURT) where it was held that unless the AO rejected the explanation or the rationale which induced the assessee to offer particular amount as expenditure with some reasoning, the mere rejection per se cannot be accepted. In this case for both years, the assessee had offered amounts as disallowance claiming them to be expenditure for tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earch assessment under Section 153A of the Act. Those appeals were rejected on the ground that no substantial question of law arose when the Court on 24.01.2018 held as follows: In these two appeals, identical questions are sought to be urged with respect to the disallowance made under Section 14A. The assessee had claimed receipt of tax exempt income by way of dividends for the relevant year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. Consequently, the principle enunciated in Taikisha Engineering (supra) clearly applied. As a result, it is held that the ITAT did not fall into error in holding as it did; no substantial question of law arises. The appeals are accordingly dismissed. For the same reasons, this appeal too is unmerited; no substantial question of law arises. The appeal is dismissed. - - TaxTMI - TM ..... X X X X Extracts X X X X X X X X Extracts X X X X
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