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TMI Blog2016 (3) TMI 1386X X X X Extracts X X X X X X X X Extracts X X X X ..... ember) The assessee is aggrieved by the impugned order dated 21/07/2014 of the ld. First Appellate Authority, Mumbai. The only ground raised in this appeal pertains to disallowing a sum of Rs. 1,38,29,156/- u/s 14A of the Income Tax Act, 1961 (hereinafter the Act) read with rule 8D of the Income Tax Rules 1962, against the dividend income of Rs. 70,03,835/-. 2. During hearing, at the outset, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer invoking Rule 8D. 3. The assessee is a non-banking finance company. The return for the year was selected for scrutiny assessment. During the course of the scrutiny assessment, the Assessing Officer noticed that the assessee has received exempt dividend income of Rs. 1,19,29,077/-. The AO further found that the assessee. has disallowed Rs. 1,81,532/- being 1% of expenses and als ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entative supported the orders of the Revenue authorities. 7. We have carefully perused the orders of the authorities below and the relevant documentary evidences brought on record before us. The assessee has made investments in financial year 2005-06 to the tune of Rs. 19.67 crores which was out of share capital received from holding company M/s. JSW Energy Ltd. amounting to Rs. 20 crores. Durin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... restrict the disallowance at Rs. 4,14,921/-. In result, the appeal filed by the assessee is partly allowed." 2.2. During hearing before us, the ld. counsel for the assessee, contended that the aforesaid reasoning contained the order may be followed in the present assessment year also. It is noted that for A.Y. 2009-10 also, there is observation that the entire investment was made out of own fun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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