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2014 (9) TMI 206 - DELHI HIGH COURTReopening of assessment u/s 147 - Expenditure u/s 14A – Proper disclosure made by assessee in front of AO - Held that:- The Tribunal rightly was of the view that the full and true details of exempt income were clearly stated and mentioned in the return of income and this fact was in the knowledge of the AO - It was, thereafter, for the AO to disallow expenditure u/s 14A of the Act – the AO may have erred, but this was not the fault of the assessee or attributable to his failure to disclose full and true material facts - Explanation to Section 147 of the Act would not be applicable - Neither the explanation invoked as the details were per se available and apparent – the order of the Tribunal is upheld – Decided against revenue.
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