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2018 (10) TMI 802 - AT - Income TaxDisallowance u/s 14A - AO considering the professional charges paid to consultants and auditors as Indirect Administrative charges for the purpose of making the disallowance - Held that:- Since the expenditure under question was not exclusively incurred to earn the exempt income. As submitted by Ld. AR, the proportion of exempt income in total income reflected in the Profit & Loss Account was 37% and therefore, the impugned disallowance would be restricted to 37% of ₹ 5,13,281/-, which comes to ₹ 1,89,914/-. The disallowance to that extent stand sustained by us. Adjustment of disallowance u/s 14A while arriving at Book Profits u/s 115JB - Held that:- We find that this issue stood squarely covered in assessee’s favor by the judgment of ACIT Vs. Vireet Investment (P.) Ltd.[2017 (6) TMI 1124 - ITAT DELHI] held that computation under clause (f) of explanation 1 to section 115 JB (2) of the Act is to be made without resorting to computation as contemplated u/s 14A of the Act r/w Rule 8D of the Rules. - Decided against revenue
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