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2022 (8) TMI 734

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..... were much higher than the investment in shares and partnership firms. There is no change in investment except increase investment to the extent of share of profit received from partnership firm. CIT(A) while restricting the disallowance under Section 14A of the Act directed the Assessing Officer to restrict the same on the basis of the Special Bench decision in case of ACIT vs. Vireet Investment P .....

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..... 2019 - - - Dated:- 20-7-2022 - SHRI P. M. JAGTAP , VICE PRESIDENT AND Ms. SUCHITRA KAMBLE , JUDICIAL MEMBER Revenue by : Shri Ramesh Kumar , Sr. DR Assessee by : Shri Biren Shah , A. R. ORDER PER SUCHITRA KAMBLE , JUDICIAL MEMBER : This appeal is filed by the Revenue and the Cross Objection is filed by the assessee against the order dated 14.08.2019 passed by the CIT(A)- .....

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..... , own and maintain and to carry on the business as keepers of cold storages, strong chambers, ice plants, refrigerators and room coolers for storing all kinds of products and to engage in the business of ware housing and to carry on business and act as promoters, organisers and developers of land, estate, property, co-operative societies, association, housing schemes, shopping office, complexes, t .....

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..... o.554 of 2017. 6. Ld. DR relied upon the Assessment Order. 7. We have heard both the parties and perused all the relevant material available on record. It is pertinent to note that the assessee claimed interest expenditure of Rs.138.27 Crores from interest free own funds in the form of share capital and reserves as well as surplus of Rs.85.67 crores on 31.03.2016 as against Rs.97.67 Crores a .....

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..... e of PCIT vs. Alembic Limited (supra) and, therefore, deleted the book profit and restricted the disallowance under Section 14A to the extent of Rs.9,06,254/-. The issue is covered and identical in the present case. The CIT(A) has rightly made the said observations and there is no need to interfere with the same. Hence, appeal of the Revenue is dismissed. 8. The Cross Objection is not pressed b .....

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