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2014 (4) TMI 394 - AT - Income TaxDisallowance u/s 14A of the Act – Held that:- As decided in assessee’s own case for the previous assessment years, it has been held that the decision in GODREJ AND BOYCE MFG. CO. LTD. Versus DEPUTY COMMISSIONER OF INCOME-TAX AND ANOTHER [2010 (8) TMI 77 - BOMBAY HIGH COURT] followed and the matter is required to be remitted back to the AO to determine the reasonable disallowance. Addition made u/s 14A of the Act – Computation of book profits u/s 115JB of the Act – Held that:- As decided in assessee’s own case for the previous assessment years, it has been held that the provisions of Rule 8D are not applicable to the present AY – thus, disallowance of expenditure by applying Rule 8D is not justified - no actual expenditure was debited in the profit and loss account relating to the earning of exempt income - the provisions of Sec. 14A cannot be imported into while computing the book profit u/s. 115JB of the Act inasmuch as clause (f) of Explanation to Sec. 115JB refers to the amount debited to the profit and loss account which can be added back to the book profit while computing book profit u/s. 115JB of the Act - the disallowance of expenses confirmed by the CIT(A) is set aside while computing book profit u/s. 115JB of the Act - no addition to the book profit shall be made for the expenditure of Rs. 113 crores while computing income u/s. 115JB – Decided in favour of Assessee.
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