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2017 (9) TMI 1973 - ITAT DELHIAddition u/s 14A - Mandation of recording of satisfaction - assessee company did not specifically pointed out any expenditure which is attributable to exempt income - CIT-A deleted the addition - HELD THAT:- As carefully perused the computation of total income and we found that there is no exempt income earned by the assessee during the year. Further more, the expression given by the assessee before the Ld. assessing officer that investment made by the assessee were only ₹ 1 5652 9018/– whereas the shareholder’s funds available with the assessee are ₹ 2 6275 1170. Therefore, the amount of investment made by the assessee for earning tax-free income are much more than the shareholders fund available with it. AO has not recorded any satisfaction with respect to the explanation of the assessee that no expenditure has been incurred by it and which is demonstrated by showing that the amount of shareholders fund available with the the assessee are more than the amount that is invested which can possibly earn the tax-free income. In view of this we agree with the contention of the Ld. authorised representative that in absence of any exempt income earned by the assessee during the year the disallowance under section 14 A of the act can not be made. - Decided in favour of assessee.
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