9911796707
TMI Blog2019 (7) TMI 182X X X X Extracts X X X X X X X X Extracts X X X X ..... r DR ORDER PER KULDIP SINGH, JUDICIAL MEMBER : Appellant, DCIT, Circle 20 (1), New Delhi (hereinafter referred to as the 'Revenue') by filing the present appeal sought to set aside the impugned order dated 21.10.2016 passed by the Commissioner of Income-tax (Appeals)-12, New Delhi qua the assessment year 2013-14 on the grounds inter alia that :- "1. "On the facts and under the circumstances o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the controversy at hand are : assessee is into the business of airlines and helicopter operators for transporting passengers, mail, cargo, freight to Indian and international tourists and is also providing charter services and consultancy services in the field of aircraft/ helicopter procurement. During the year under assessment, assessee filed return of income declaring loss of Rs. 10,24,88,4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orders passed by the revenue authorities below in the light of the facts and circumstances of the case. 5. Ld. DR for the Revenue challenging the impugned order contended inter alia that the AO has worked out the disallowance under Rule 8D as per accounts rendered by the assessee having been duly explained at the second last page of the assessment order; that section 114 of the Evidence Act, 1872 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r assessment on the investment made. When we examine the impugned order passed by the ld. CIT (A), we find that he has deleted the addition made on account of disallowance made u/s 14A of the Act on the premise that the assessee has not earned any exempt income during the year under assessment, hence no disallowance can be made u/s 14A of the Act. This issue has been repeatedly decided by Hon'ble ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned order passed by the ld. CIT (A) is not applicable to the facts and circumstances of this case. So, we are of the considered view that the ld. CIT (A) has rightly arrived at the decision that when there is no exempt income earned by the assessee during the relevant assessment year, no disallowance can be made by invoking the provisions contained u/s 14A of the Act. So, finding no illegality or ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
