TMI Blog2019 (4) TMI 1578X X X X Extracts X X X X X X X X Extracts X X X X ..... nvoked ? - HELD THAT:- We find that the assessee has raised a specific ground that the investments were made to gain control of the subsidiary companies and therefore, it is its business expediency. The assessee however, relied upon the contentions before the authorities below. Therefore, the ground No.4 on this issue is rejected. Respectfully following the decision of the Coordinate Bench in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the facts and in the circumstances of the case, the order of Commissioner of Income Tax (Appeals)-4, Hyderabad, dismissing the appeal of the Appellant is erroneous, illegal and unsustainable both on facts and in law. 2. The Commissioner (Appeals) erred in sustaining the disallowance of ₹ 12,74,97,099 under section 14A of the Act read with Rules. The Commissioner (Appeals) fa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... For these and other grounds that may be urged at the time of hearing it is prayed that the appeal may be allowed . 2. However, at the time of hearing, the learned Counsel for the assessee submitted that the disallowance made by the assessee u/s 14A was only a sum of ₹ 8,96,66,476/- whereas in the ground it was erroneously mentioned as ₹ 12,74,97,099/- and req ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e provisions of section 14A r.w.r 8D are applicable. 4. Having regard to the rival contentions and the material on record, we find that the assessee has raised a specific ground that the investments were made to gain control of the subsidiary companies and therefore, it is its business expediency. The learned Counsel for the assessee however, relied upon the contentions before the a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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