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Originally the assessee took three grounds of appeal, wherein it has challenged confirmation of disallowance of Rs. 2,97,347/- made by the AO under section 14A of the Income Tax Act, 1961 r.w rule 8D(2)(iii) of the Income Tax Rules. However, during the pendency of the appeal the assessee has raised additional grounds of appeal whereby it has pleaded that the assessee has made disallowance of Rs. 59,55,723/- under section 14A suo motto.

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Sec. 14A of Income Tax Act, 1961—Business Disallowance —ARDOR-IN-FIN P LTD. vs. ITO.[2020] 25 ITCD Online 084 (ITAT-AHMEDABAD)