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2015 (6) TMI 313 - AT - Income TaxDetermination of net taxable income - CIT(A) allowing revenue expenditure to be set off against quantum of subsidy receipts from the Government disclosed at ₹ 5,04,04,286/- - whether the subsidy received is not covered u/s 14A as the same is merely a reimbursement of expenses by the Government and is not in the nature of income of the assessee? - Held that:- Since the entire income of the assessee had been held to be non-agriculture income, hence all the expenses incurred on purchase of seeds, transportation to remote areas like Jammu & Kashmir, Srinagar etc. would constitute revenue expenditure and ought to be deducted from the revenue receipts. Therefore, ld. CIT(A) had directed the AO to determine the net taxable income after verifying the revenue expenditure and allowing the same to be set off against the revenue receipts of ₹ 5,04,04,286/- i.e. the quantum of subsidy received. We, therefore, do not find any infirmity in the order of ld. CIT(A) on this count. As we have held that there is no exempt income, therefore, the question of applicability of section 14A, in any case, does not arise. - Decided against revenue.
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