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2014 (7) TMI 306 - AT - Income TaxDisallowance u/s 14A of the Act – Dividend income - Tax Audit Report – Held that:- The relevant AY is 2007-08 under consideration is outside the scope of provisions of Rule 8D - The provisions cannot be treated as applicable to the AY 2006-07 under consideration, as it is already decided in Godrej & Boyce Mfg. Co. Ltd. Vs. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] - percentage of the exempt income can constitute a reasonable estimate for making disallowance in the years earlier to the assessment year 2008-09 - the disallowance made by the assessee is in accordance with the judgment in the case of M/s. Godrej Agrovet which is more than 2% and therefore, no addition is call for – Decided in favour of Assessee.
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