Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2014 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (7) TMI 256 - AT - Income TaxDisallowance u/s 14A r.w Rule 8D of the Rules – Interest on exempt income – Held that:- CIT(A) rightly held that the interest expenditure that could be considered for disallowance was to be the net amount of interest which the assessee had to incur - the source of income and the destination of expenditure were same and when both had a direct nexus with the earning of exempt income, the expenditure in that regard would be that which was actually incurred by the assessee - the assessee had himself disallowed all the expenditure claimed to be incurred by him - CIT(A) after proper appreciation of the facts has categorically held that there was a direct nexus between loan, interest paid on loan amount, the interest received on margin money as well the investments made – thus, CIT(A) rightly held that the assessee was right in his action in netting the interest received against the interest paid, while calculating the interest expenditure incurred for the purpose of investments as the source of money for investment and the destination of expenditure were the same – thus, there was no infirmity in the order of the CIT(A) – Decided against Revenue.
|