TMI Blog2021 (5) TMI 717X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee by the ld. CIT (A) by treating the appeal to be infructuous, we find merit in the same. The issue in the appeal against the order U/s. 154 of the Act was with respect to invoking the provisions of section 14A of the Act by computing the taxable income of the assessee U/s. 115JB of the Act. Therefore, we do not find it to be of any relevance with respect to the issue raised in the appeal before the Ld. CIT (A) which is on invoking the provisions of section 14A of the Act while computing the taxable income under the normal provisions of the Act. Hence, it is evident that the Ld. CIT (A) has not addressed the ground raised in the appeal. However as per on an earlier occasion on the identical issue of invoking the provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion made towards the book profit U/s. 115JB of the Act invoking section 14A of the Act. 3. The brief facts of the case are that the assessee is a Private Limited Company engaged in the business of manufacturing engineering goods filed its return of income on 1/10/2013 declaring NIL income as per normal provisions of the Act and ₹ 2,20,93,000/- U/s. 115JB of the Act. Initially, the case was processed U/s. 143(1) of the Act and thereafter the case was taken up for scrutiny as per the norms of CASS. Finally, the assessment was completed U/s. 143(3) of the Act vide order dated 29/2/2016 wherein the Ld. AO made addition of ₹ 57,26,865/- invoking the provisions of section 14A of the Act and also disallowed amount of ₹ 14, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al submissions and carefully perused the material available on record. With respect to the arguments advanced by the ld. AR dismissing the appeal of the assessee by the ld. CIT (A) by treating the appeal to be infructuous, we find merit in the same. The issue in the appeal against the order U/s. 154 of the Act was with respect to invoking the provisions of section 14A of the Act by computing the taxable income of the assessee U/s. 115JB of the Act. Therefore, we do not find it to be of any relevance with respect to the issue raised in the appeal before the Ld. CIT (A) which is on invoking the provisions of section 14A of the Act while computing the taxable income under the normal provisions of the Act. Hence, it is evident that the Ld. CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s for making investment in its own subsidiary company, no interest cost can be attributable to the same because, there is no interest cost to the assessee, as it can be treated that the assessee has withdrawn from its capital and reserves which are assessee s interest free funds for making such investment. Further, for making investment in its own company there cannot be any cost attributable with respect to direct and indirect expenses towards the process of decision making, due diligence, managerial expenditure and portfolio management expenditure because no such cost can arise for making investment in one s own entity. Further, only meagre expenses can be attributable with respect to clerical and stationary expenses which is negligible a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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