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TMI Blog2021 (10) TMI 438X X X X Extracts X X X X X X X X Extracts X X X X ..... PER MAHAVIR SINGH, VP: This appeal filed the assessee is arising out of the order of Commissioner of Income Tax (Appeals)-8, Mumbai [in short CIT(A)], in Appeal No. CIT(A)-8/IT-38/2017-18 vide order dated 10.07.2019. The Assessment was framed by the Dy. Commissioner of Income Tax, Circle 3(3)(1), Mumbai (in short 'DCIT/ AO') for the A.Y. 2015-16 vide order dated 13.06.2017 under section 143(3) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1.2 It is submitted that no part of interest expenditure is to be disallowed as it has direct nexus with interest income. It is submitted that the disallowance under Section 14A of the Act computed by the Learned Assessing Officer and confirmed by the CJT(A) is excessive, unreasonable and unwarranted. 1.3 It is submitted that the Learned CIT(A) and learned Assessing Officer erred in disallowing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of the Assessing Officer. Aggrieved, assessee came in appeal before Tribunal. 4. We noted from the details filed by the assessee and the audited accounts of the assessee that the assessee has sufficient own funds in the form of share capital and reserves and surplus amounting to Rs. 16,02,67,705/- as on 31.03.2015 as against the investment of Rs. 15,96,06,706/- in the shares of mutual funds. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (2)(ii) of the Rules can be made unless and until the Assessing Officer has able to prove the direct nexus. Hence, we delete the disallowance and reverse the orders of the lower authorities on this issue. 6. Coming to the second disallowance of administrative expenses made by Assessing Officer and confirmed by CIT(A) amounting to Rs. 5,95,854/- under Rule 8D(2)(iii), the learned counsel for the a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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