TMI Blog2019 (9) TMI 1481X X X X Extracts X X X X X X X X Extracts X X X X ..... of Patiala ( 2018 (11) TMI 1565 - SC ORDER) we do not find any reason to interfere with the order of the Ld.CIT(A) and hence dismiss the revenue s appeal. - ITA No.568/Chny/2019 - - - Dated:- 27-9-2019 - SHRI DUVVURU R.L. REDDY, JUDICIAL MEMBER AND SHRI S. JAYARAMAN, ACCOUNTANT MEMBER For the Department : Mr. R.Clement Ramesh Kumar, Addl.CIT For the Assessee : Mr. R.Sivaraman, A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hough, the assessee claimed the sources for the investment was out of interest free loan taken from its group concerns M/s.Shamani Management Services Pvt. Ltd, the AO found that the assessee took a loan of ₹ 75 Crs. from M/s.Shriram City Union Finance Ltd., at the interest cost of ₹ 7,24,71,575/- and repaid the loan taken from M/s.Shamani Management Services Pvt. Ltd. Therefore, the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,58,225/- only during the assessment year from M/s.Tech Solutions Ltd., he restricted the disallowance u/s.14A to ₹ 2,58,225/- and thus, partly allowed the appeal. 4. Aggrieved against that order, the Revenue filed this appeal with the following grounds: 1 The CIT(A) erred in directing the AO to restrict the disallowance to the earning of exempted income. 2 The CIT(A) ought to have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AR supported the order of the Ld.CIT(A). 6. We heard the rival submissions and gone through the relevant materials. Since the Ld. CIT(A) followed the decision of the Hon ble Supreme Court in the case of PCIT v. State Bank of Patiala, supra, we do not find any reason to interfere with the order of the Ld.CIT(A) and hence dismiss the revenue s appeal. 7. In the result, the appeal filed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
