TMI Blog2014 (4) TMI 1261X X X X Extracts X X X X X X X X Extracts X X X X ..... find merit in the submissions made by the assessee that in view of non application of the provisions of Rule 8-D of the Income Tax Rules to the concerned assessment year, there is no merit in disallowance made by AO on the surmises that the assessee had borrowed funds in one hand and had invested in tax free assets on the other hand. We uphold the order of the CIT (Appeals) in disallowing S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he order of the Commissioner of Income Tax (Appeals)-II, Ludhiana dated 14.10.2013 relating to assessment year 2001-02 against the order passed under section 143(3) of Income Tax Act, 1961 (in short the Act ). 2. The Revenue has raised the following grounds of appeal: 1. That the Ld. CIT(A) has erred in law and facts in allocating the expenses of ₹ 1 lac only as against of ₹ 31 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r similar disallowance has been upheld by the Hon'ble Punjab Haryana High Court in assessee own case in ITA No.141 of 2012, decided on 31.7.2013. 5. The learned D.R. for the Revenue placed reliance on the order of the Assessing Officer. 6. We have heard the rival contentions and perused the record. The issue arising in the present appeal is against the disallowance of expenses being at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s on the other hand. However, we uphold the order of the CIT (Appeals) in disallowing ₹ 1 lac on account of administrative expenses as being attributable to the earning of tax free income. We further find that similar disallowance of ₹ 1 lac in assessee s hands was made in the preceding year and the order of the Tribunal has been upheld by the Hon'ble Punjab Haryana High Court in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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