TMI Blog2017 (11) TMI 1859X X X X Extracts X X X X X X X X Extracts X X X X ..... PER NK SAINI, ACCOUNTANT MEMBER This is an appeal filed by the assessee against the order of the Ld.CIT(I), New Delhi dated 18.8.2015. The following grounds have been raised in this appeal. l(a) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals) [CIT(A)] having held that provisions of section 14A read with rule 8D are not applicable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... egard to additional disallowance of Rs. 2,50,038/- u/s 14A made by the Ld. A.O. The appellant craves leave to add, alter, amend and/or modify all or any of the above grounds of appeal on or before the date of hearing. 2. During the course of hearing the Ld.Counsel for the assessee at the very outset stated that the issue under consideration is covered in favour of the assessee vide order dt. 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 88, wherein the Tribunal in paras 22 to 24 has observed as under. We have considered the rival contentions and gone through the records. The provisions of section 44 read as under. 'Insurance business, - 44 : Notwithstanding anything to the contrary contained in the provisions of this Act relating to the computation of income chargeable under the head 'interest on securities', 'income from h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lance of profits disclosed by the annual accounts as furnished to the Controller of Insurance. The actual computation of profits and gains of insurance business will have to be computed in accordance with Rule 5 of the First Schedule. In the light of these special provisions coupled with non obstante clause the AO is not permitted to travel beyond these provisions. 24. Section 14A contemplates ..... X X X X Extracts X X X X X X X X Extracts X X X X
|