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2012 (8) TMI 487 - ITAT, MUMBAIDisallowance of deduction u/s 10A - assessee had not allocated the common headquarter expenses aggregating to the 10A unit - Assessee has argued that attribution of expenses of the head office on turnover basis is not correct - Held that:- The head office caters to the needs of all the units and therefore the head office expenses are required to be attributed to the various units and attribution of expenses based on turnover is quite appropriate. While working out the profit of the unit, the indirect expenses incurred in the head office have therefore, been correctly attributed on the basis of turnover - against assessee. Disallowance of expenses under section 14A r.w.r. 8D - Held that:- Rule 8D is applicable only from assessment year 2008-09 and, in respect of prior years, expenses relating to exempt income both direct and indirect have to be computed on a reasonable basis after allowing opportunity of hearing to the assessee - as in this case, CIT (A) has directed the AO to compute the disallowance after allowing opportunity of hearing to the assessee no infirmity in the order of CIT(A) of disallowance - against assessee.
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