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2015 (3) TMI 1260 - ITAT MUMBAIDisallowance under Rule 8D(2)(iii) sec 14A - Held that:- As found from the record that assessee itself has made a suo motu disallowance of ₹ 1 lakh under Rule 8D(2)(iii), however, the AO has computed disallowance under Rule 8D(2)(iii) at ₹ 2,14,85,474/-. The assessee company is basically engaged in the construction activity having total receipts of ₹ 3229.76 crores out of which dividend income is only ₹ 9.68 crores, which works out to be 0.309% of the total receipts. We found that out of total dividend income of ₹ 9.86 crores, the assessee received dividend income of ₹ 8 crores from the group concern only which do not require any extra efforts on account of administrative expenses etc. Accordingly, we do not find any infirmity in the order of CIT(A) for upholding the disallowance of ₹ 10 lakhs under rule 8D(2)(iii) which was claimed by the assessee at ₹ 1 lakh.
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