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2020 (7) TMI 187

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..... t of interest u/s 14A as worked out by applying Rule 8D(2)(ii) thus is not sustainable and direct the AO to delete the same. Disallowance on account of other expenses u/s 14A r.w.r. 8D(2)(iii) - assessee has contended that the same is required to be worked out by taking into consideration only the value of investment in shares which actually fetched the exempt dividend income to the assessee .....

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..... 59 - ITAT MUMBAI ] - I.T.A. No. 2061/Kol/2019 - - - Dated:- 22-5-2020 - Shri P.M. Jagtap, Vice President (KZ) For the Assessee : Shri P.J. Bhide, FCA For the Revenue : Shri Baijnath Singh, JCIT, Sr. DR ORDER This appeal filed by the assessee is directed against the order of Ld. CIT(A) 10, Kolkata dated 26.06.2019 and the solitary issue involved therein relates to the disa .....

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..... the profit and loss account were ₹ 6,07,313/- only, he made a disallowance of ₹ 6,07,313/- u/s 14A of the Act. On appeal, the CIT(A) sustained the said disallowance made by the AO u/s 14A. Aggrieved by the order of the Ld. CIT(A), the assessee has preferred this appeal before the Tribunal. 3. I have heard the arguments of both the sides on this issue and also perused the relevant ma .....

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..... the value of investment in shares which actually fetched the exempt dividend income to the assessee and not the value of entire investment as done by the AO. Since this contention of the learned counsel for the assessee is duly supported by the decision of Hon ble Kolkata High Court in the case of REI Agro Ltd. GA No. 3022 of 2013 (ITAT No. 161 of 2013) judgement dated 23.12.2013, we direct the AO .....

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