TMI Blog2017 (8) TMI 1620X X X X Extracts X X X X X X X X Extracts X X X X ..... icable, because prima facie Section 14A warrants that the assessee should have incurred some expenditure in relation to the income which does not form part of the total income under the Act. There will be no overhead cost to the assessee when it decides to invest in its own sister companies for strategic reasons at least in the case of the assessee firm before us. However if the assessee had ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enon,Advocate For the Respondent : Shri B. Sagadevan, JCIT ORDER This appeal by the assessee is directed against the order passed by the Ld. Commissioner of Income Tax (Appeals)-2, Chennai dated 31.01.2017 in ITA No.192/CIT(A)-2/2015-16 for the assessment year 2013-14 passed U/s.250(6) r.w.s.143(3) of the Act. 2. The assessee has raised several grounds in its appeal, however the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assessee had made investments in equity shares of its sister concerns and therefore the assessee had not incurred any expenditure towards such investments. Hence, it was pleaded that the provision of Section 14A will not be applicable in the case of the assessee. The Ld.DR on the other hand relied on the orders of the Ld.Revenue Authorities. 5. I have heard the rival submissions and c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny other activities of the assessee bearing taxable income. Since the Ld.AR had pointed out to us that the assessee had made the investments in its sister concerns for strategic reasons out of its own interest free funds, I find it appropriate to remit the matter back to the file of Ld.AO for fresh consideration and to pass appropriate order in accordance with law and merit and based on our above ..... X X X X Extracts X X X X X X X X Extracts X X X X
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