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2019 (7) TMI 355

nd the assessee has demonstrated the source of fund and no disallowance is required on account of administrative expenses for managing PPF account. Therefore, addition to the extent of ₹ 29,989/- deserves to be deleted. We delete accordingly. Addition of Dividend income - Contentions of the assessee is that she has capital out of which it can be alleged that she made investment - HELD THAT:- Proprietor’s capital has been shown at ₹ 42,08,954/- as on 31.3.2012, but her investments are more than this. Her total investment was at ₹ 1,33,52,645/-. Against immovable properties she has shown investment of ₹ 9,98,150/-. Now what are these immovable properties, is not ascertainable, and what is the source of these, is .....

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s allowance of ₹ 9600/- which has been received by the assessee as transport allowance. Appeals of the assessee are partly allowed. - ITA No.638 and 640/Ahd/2018 - 5-7-2019 - Shri Rajpal Yadav, Judicial Member And Shri Amarjit Singh, Accountant Member For the Assessee : None For the Revenue : Shri Keyur Patel, Sr.DR ORDER PER RAJPAL YADAV, JUDICIAL MEMBER: The ld.CIT(A) has decided two appeals of the assessee for the Asstt.Years 2012-13 and 2014-15 by way of separate orders passed on 9.1.2018. The assessee is challenging both these orders in the present appeals. Sole grievance of the assessee is that the ld.CIT(A) has erred in confirming the addition of ₹ 76,614/- and 84,825/- which were added by the AO under section 14A of the .....

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istance of the ld.DR, we have gone through the record carefully. A perusal of the paper book would indicate that the assessee has filed written submissions in both the years. We take note of the written submissions, which read as under: Asstt.Year 2012-13: Respected Sir, Reg: I.T.A. No.638 /AHD/2018 for Assessment Year 2012-13 in the matter of Shilpa Ajaykumar Parasrampuria Sub: Written Submission With reference to the above captioned subject, we plea for the following points:- 1. Addition of PPF Interest amounting to ₹ 29,989/-. We have received PPF maturity amount of ₹ 6,27,595/- as on 08.11.2011. ( Refer page No. 36) The PPF maturity passbook also mentioned amount of ₹ 6,27,595/-.(Refer page no. 36) The bank statement o .....

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0(14)(ii). 4. At the time of filling of return, presentation of Transport Allowance was done wrongly as Exempt Income, which hadn't affect on taxable income of Assessee.(Refer page no. 0) 5. There is no relevant ground for disallow such exempt allowance. 5. As far as Asstt.Year 2012-13 is concerned, the assessee has objected for disallowance of PPF interest amounting to ₹ 29,989/-. According to the assessee, she has made investment in PPF account after receiving maturity amount earlier invested. To our mind the assessee has demonstrated the source of fund and no disallowance is required on account of administrative expenses for managing PPF account. Therefore, addition to the extent of ₹ 29,989/- deserves to be deleted. We d .....

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in the shape of dividend then also expenses relatable to exempt income are required to be calculated and disallowed. Therefore, in the Asstt.Year 2012-13, we allow the appeal of the assessee partly and confirm the disallowance at ₹ 46,625/-. 7. As far as Asstt.Year 2014-15 is concerned, the assessee failed to give any plausible explanation as to how the expenses are not required to be disallowed. The ld.CIT(A) has examined this issue in detail. She has made investment in the mutual fund to the extent of ₹ 94,54,500/- in the financial year 2013-14. She has failed to show that such investment was made out of interest free funs. The AO has rightly worked out the disallowance under section 14A. The only amount which requires to be e .....

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