TMI Blog2022 (6) TMI 66X X X X Extracts X X X X X X X X Extracts X X X X ..... utation submitted, quantified the disallowance at Rs.1,244/- as mentioned earlier, in foregoing paragraph (B) of this order. The Assessing Officer is directed to verify this computation at the time of giving effect to this order. The Assessing Officer is further directed to provide reasonable opportunity to the assessee to explain the computation, and to make submissions, in case computation presented by the assessee s side in accordance with Rule-8D of Income Tax Rules is not accepted by the Assessing Officer. - ITA No. 7917/Del/2018 - - - Dated:- 12-5-2022 - SHRI KUL BHARAT , JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA , ACCOUNTANT MEMBER Appellant by : Sh. Atul Ninawat , CA Respondent by : Sh. Prabhat Ranjan , Sr. DR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ad hoc disallowance was computed by the Assessing Officer at Rs.Rs.4,10,295/- being 20% of exempt income (dividend income) of Rs.20,51,473/-. This disallowance of Rs.4,10,295/- was upheld by the Ld. Commissioner of Income Tax (Appeals)-35, New Delhi ( Ld. CIT(A) for short) vide impugned appellate order date 20.09.2018. The present appeal has been filed by the assessee against the aforesaid impugned appellate order dated 20.09.2018 of the Ld. CIT(A). In the course of appellate proceedings in Income Tax Appellate Tribunal in the present appeal before us, the paper book was filed from the assessee s side, containing the following particulars: S. PARTICILARS (A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Detailed breakup of Investment held by Appellant 14 Order of Ld. AO for AY 2011-12 in case of Appellant 15 Order of Hon'ble ITAT for AY 2014-15 dated 13.01.2022 in case of Appellant 16 Order of Hon'ble ITAT for AY 2012-13 dated 31.03.2021 in ease of Appellant 17 Order of Hon'ble ITAT for AY 2013-14 dated 23.02.2021 in case of Appellant 18 Order of Hon'ble ITAT for AY 2011-12 dated 25.11.2019 in case of Appellant 19 Order of Hon'ble ITAT for AY 2008-09 2009-10 da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee drew our attention to page 177 of the Paper Book, wherein the quantum of disallowance u/s 14A of IT Act, computed in accordance with method prescribed under Rule 8D of IT Rules, was quantified at Rs.1,244/- (B.1) The Ld. Senior Departmental Representative ( Ld. SR-DR for short), supported the orders of the Ld. CIT(A) and the Assessing Officer. However, the Ld. Sr. DR could not justify how the ad hoc disallowance made by the Assessing Officer @ 20% of exempt income, was a reasonable disallowance in the facts and circumstances of the case. (B.2) We have heard both sides. We have perused the materials on record. We find from the perusal of the orders of the Ld. CIT(A) and the Assessing Officer that there is no justification to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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