TMI Blog2019 (6) TMI 94X X X X Extracts X X X X X X X X Extracts X X X X ..... isallowance u/s 14A is attracted. See WINSOME TEXTILE INDUSTRIES LTD. [ 2009 (8) TMI 220 - PUNJAB AND HARYANA HIGH COURT] ,CHEMINVEST LIMITED [ 2015 (9) TMI 238 - DELHI HIGH COURT] , CORRTECH ENERGY PVT. LTD. [ 2014 (3) TMI 856 - GUJARAT HIGH COURT] So far as the contention of DR that the assessee himself had agreed during the assessment proceedings when called for by the Assessing officer f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Singh, Sr. DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order dated 25.01.2018 of the. Commissioner of Income Tax (Appeals) 3, Ludhiana [hereinafter referred to as CIT(A) ] agitating the action of the lower authorities in making / confirming of disallowance of ₹ 67,955/- u/s 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e by the Assessing officer. 4. At the outset, the Ld. Counsel for the assessee has submitted that the assessee has not earned tax exempt income during the year. He has relied upon the various decisions of the Hon'ble High Courts including that of the Jurisdictional High Court of Punjab and Haryana in the case of CIT Vs. Winsome Textiles (2009) 319 ITR 204 (P H) and Hon'ble ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt proceedings when called for by the Assessing officer for making the aforesaid disallowance u/s 14A of the Act is concerned, we are not convinced with the above submissions of the Ld. DR. If the assessee under the mistaken belief had agreed to the aforesaid disallowance, that itself, does not debar the assessee to agitate the said disallowance in an appeal if the assessee otherwise legally is no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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