TMI Blog2021 (7) TMI 504X X X X Extracts X X X X X X X X Extracts X X X X ..... his order and accordingly, prayed for restoring of this matter to the file of Ld. AO for de novo adjudication in accordance with law. We find that the law on this issue u/s. 14A of the Act is well settled as on date. We direct the Ld. AO to consider only those investments which had actually yielded exempt income to the assessee while doing the de novo assessment on the issue of disallowance u/s. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red to as 'AO') on 24.12.2010 and 29.09.2011 for assessment years 2008-09 and 2009-10 respectively u/s. 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'Act'). 2. We find that the assessee had explained that in view of Covid-19 Pandemic, these cross-objections could not be filed in time before this Tribunal. Considering the same, we are inclined to condone the del ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ereon would apply with equal force for assessment year 2009-10 also, in view of identical facts except with variance of figures. 3.1. The return of income for the assessment year 2008-09 was filed by the assessee declaring loss of ₹ 3,92,97,426/-, which was duly processed u/s. 143(1) of the Act. The original assessment was completed u/s. 143(3) of the Act for assessment year 2008-09 on 24 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ore the Ld. AO. We find that the Ld. AO observed that the disallowance voluntarily made by the assessee was not in accordance with the computation mechanism provided in Rule 8D(2)of the Rules and accordingly proceeded to make the disallowance as under: Under Rule 8D(2)(ii) ₹ 43,48,646/- Under Rule 8D(2)(iii) &# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted by the Ld. CIT(A) in his order and accordingly, prayed for restoring of this matter to the file of Ld. AO for de novo adjudication in accordance with law. We find that the law on this issue u/s. 14A of the Act is well settled as on date. We direct the Ld. AO to consider only those investments which had actually yielded exempt income to the assessee while doing the de novo assessment on the iss ..... X X X X Extracts X X X X X X X X Extracts X X X X
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