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| The Tax Publishers2020 TaxPub(DT) 3446 (Del-Trib) INCOME TAX ACT, 1961
Section 14A(2)
Where dissatisfaction recorded by AO on correctness of claim of expenditure under section 14A was not proper within requirements of section 14A(2), disallowance made under section 14A read with rule 8D(2)(iii) was deleted.
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Disallowance under section 14A - Expenditure against exempt income - Non-recording of proper dissatisfaction in terms of section 14A(2) -
Assessee challenged disallowance made under section 14A read with rule 8D(2)(iii) on the ground of AO not having proper dissatisfaction in terms of section 14A(2). Held: AO recorded that assessee made heavy investment for earning of exempt income and expenses for earning exempt income like manpower, vehicle, telephone, use of Internet, computer and its depreciation, electricity, etc., must have been incurred by assessee. But, AO was not specific as to what exactly the probable expenditure in the matter. Accordingly, dissatisfaction recorded by AO on correctness of claim of expenditure was not proper within requirements of section 14A(2) and disallowance was deleted.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 37(1)
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