SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

24. On careful consideration of the above rival submissions, order of ITAT, Special Bench in the case of Vireet Investment Pvt. Ltd. (supra) and orders of the authorities below we find that the ld.CIT(A) has decided the issue partly confirming the disallowance made by the AO u/s 14A of the Act r.w.r 8D(2)(iii) of the Rules with