TMI Blog2017 (5) TMI 1554X X X X Extracts X X X X X X X X Extracts X X X X ..... for the purposes of considering the amount of tax effect as envisaged in CBDT Circular dated 10/12/2015 what has to be considered is the amount of tax excluding the amount of surcharge and education cess. Therefore, in this view of the matter, the tax effect in dispute in the captioned appeal is stated to be below the monetary limit of ₹ 10.00 lacs specified in the CBDT Circular dated 10/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... #8377; 33,67,807/- under section 14A of the Income tax Act, 1961 ignoring the fact that working of disallowance u/s.14A read with rule 8D is mandatory from A. Y.2008-09 onwards, as held by jurisdictional High Court in Godrej Boyce Mfg. Co. Limited. (328 ITR 81), further the purpose for which shares are held / purchased could not in any manner impact of applicability of Section 14A, as held by Ho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nue in appeal before us is ₹ 32,87,971/-. The tax effect on this disputed income comes to ₹ 9,86,391/-, excluding the surcharge and education cess of ₹ 1,31,190/-. Our Co-ordinate Bench in the case of DCIT vs. M/s. Dome Bell Electronics India Ltd., in ITA No.2480/Mum/2012 dated 22/07/2016 has held that for the purposes of considering the amount of tax effect as envisaged in CBDT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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