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2013 (4) TMI 487 - AT - Income TaxDisallowance of expenditure related to Exemption u/s. 10(36) in respect of dividend income - Section 14A - Disallowance Under Rule 8D - Held that:- The question arising in the present appeal is primarily of fact, i.e., the amount of indirect expenditure by way of administration expenses that can be reasonably attributed to the exempt - The orders of both the authorities are silent in the matter - The Revenue has also not brought on record its figure, with reference to which only, coupled withother relevant information, the reasonability or otherwise of the disallowance, which is being impugned by the Revenue, could be adjudged by us. The disallowance at Rs.10,000/-, which works to 6.17% of the exempt income, cannot be held as unreasonable, particularly considering that there is nothing adverse on record, and the fact that the tribunal has in the cited cases found a disallowance at as low as 2% to 5% of such (exempt) income as sustainable. No interference with the impugned order is, therefore, called for. We decide accordingly.
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