TMI Blog2023 (7) TMI 513X X X X Extracts X X X X X X X X Extracts X X X X ..... he question (a) as under: (a)Whether on the facts and circumstances of the case and in law the Hon'ble the ITAT was right, in deleting the disallowance under Section 14A r.w.s. Rule 8D when no exempt income was earned by the Assessee? Addition u/s 36(1)(iii) - assessee was unable to prove the commercial expediency as narrated in the factual legal matrix clearly brought out in assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er: (a) Whether on the facts and circumstances of the case and in law the Hon'ble the ITAT was right, in deleting the disallowance of Rs. 8,58,32,156/- under Section 14A r.w.s. Rule 8D without properly appreciating the factual and legal matrix as clearly brought out by the Assessing Officer? (b) Whether on the facts and circumstances of the case and in law the Hon'ble IT AT was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed are almost identical. 3. We admit the Appeal on the question (a) as under: (a)Whether on the facts and circumstances of the case and in law the Hon'ble the ITAT was right, in deleting the disallowance of Rs. 8,58,32,156/- under Section 14A r.w.s. Rule 8D when no exempt income was earned by the Assessee? 4. As regards proposed question (c), it involves on factual matrix. Respon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... allowable and hence, disallowed difference between Rs. 12,39,80,822/- and Rs. 8,70,00,000/- totalling to Rs. 3,69,80,822/-. 5. CIT (A) as well as ITAT have accepted that entire interest expenses of Rs. 12,39,80,822/- has to be allowed in toto under section 36(1)(iii) as well as under section 37(1) as being for the purpose of business and the same was undoubtedly and undisputedly taken for the p ..... X X X X Extracts X X X X X X X X Extracts X X X X
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