IN THE ITAT, AHMEDABAD BENCH
MAHAVIR PRASAD, J.M. & WASEEM AHMED, A.M.
Yesha Electricals (P) Ltd. v. Addl. CIT
I.T.A. No(s). 2280/Ahd/2013, 133/Ahd/2014, 271/Ahd/2015, 627/Ahd/2016, 455/Ahd/2017
26 October, 2020
Assessee by: Manish J. Shah, AR
Revenue by: Dileep Kumar, Sr. DR
Waseem Ahmed, A.M.
In this bunch of appeals all appeals have been filed by the assessee for assessment years 2009-10 to 2013-14 which are arising from the separate orders of the Commissioner (Appeals)-III Baroda, Commissioner (Appeals)-2, Vadodara, Commissioner (Appeals)-I, Baroda, dated 24-6-2013, 13-11-2013, 11-11-2014, 5-1-2016, 20-12-2016 in the assessment proceedings under section 143(3) of the Income Tax Act, 1961 (in short 'the Act').
First, we take the ITA No. 2280/AHD/2013 for the assessment year 2009-10
2. The first interconnected issue raised by the assessee is that the learned Commissioner (Appeals) erred in confirming the order of the assessing officer by sustaining the disallowance of Rs. 13,26,591 under the provisions of section 14A read with rule 8D of Income Tax Rules.
3. The facts in brief are that the assessee in the present case is a private limited company and engaged in the business of manufacturing of electrical engineering products. The assessee in the year under consideration has shown dividend income of Rs. 55,54,823 and share of profit from the firm Rs. 1,13,080 which was claimed as exempted income. The assessee against such exempted income has made Suo Moto disallowance of the expenses as detailed under :--