AALIDHARA TEXTOOL ENGINEERS PVT. LTD,SURAT vs. PCIT-1, SURAT
In the result, the appeal of the assessee is allowed
ITA 94/SRT/2020[2014-15]Status: DisposedITAT Surat28 May 2021AY 2014-15
Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.94/Srt/2020 ("नधा"रणवष" / Assessment Years: (2014-15) (Virtual Court Hearing) Alidhara Textool Engineers Pvt. Ltd., Vs. The Pcit-1, Surat. Plot No.168, Udhyog Nagar Road, Udhna, Surat -394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8469M (Assessee) (Respondent)
For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 10Section 10(38)Section 115JSection 143(3)Section 14ASection 263
section 263 of the Income Tax
Act, 1961. On perusal of Scrutiny records, it was observed by ld PCIT that while computing disallowance u/s 14A by applying formula under Rule 8D item (iii) being percent of average investment, investment in partnership firm M/s.
Gokulanand Petro Fibers was not considered. The PCIT noted that assessee has received share of profit