| The Tax Publishers2020 TaxPub(DT) 3847 (Mad-HC) Income Tax Act, 1961
Section 14A
Tribunal re-appreciating the factual matrix noticed that investment during the year increased from Opening Balance of Rs. 3,21,68,40,000 to Closing Balance of Rs. 5,17,93,70,000. Further, Tribunal noticed that value of the assets also increased substantially to Rs. 1,84,18,32,000 from Rs. 1,76,96,30,000 and ,therefore, AO applied rule 8D and made additions under section 14A and accordingly, there was no error in the order of AO as confirmed by the Tribunal.
|
Disallowance under section 14A - Expenditure against exempt income - Substantial increase in investments during the year but no disallowance claimed under section 14A -
Assessee earned tax free dividend income on investments in shares and claimed that no expenditure was incurred for earning the exempt income. AO invoked section 14A read with rule 8D and worked out disallowance. Assessee challenged this. Held: Tribunal re-appreciating factual matrix noticed that investment during the year increased from opening Balance of Rs. 3,21,68,40,000 to closing Balance of Rs. 5,17,93,70,000. Further, Tribunal noticed that value of the assets also increased substantially to Rs. 1,84,18,32,000 from Rs. 1,76,96,30,000 and ,therefore, AO applied rule 8D and made additions under section 14A and accordingly, there was no error in the order of AO as confirmed by Tribunal.
REFERRED :
FAVOUR : Against the assessee
A.Y. : 2010-11
Section 10A
 SUBSCRIBE FOR FULL CONTENT
|