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2015 (10) TMI 1488 - AT - Income TaxDisallowance under section 14A - expenditure incurred for earning of exempt income - Held that:- The straightway application of rule 8D in the case of the assessee by the lower authorities is not sustainable. Taking into consideration the overall facts and circumstances of the case especially the nature of investments made by the assessee and further that most of the investments were made in earlier years, in our view, the expenses equal to 2% of the exempt income earned by the assessee would constitute a reasonable disallowance and the same is restricted to that extent accordingly. This ground of appeal of the assessee is thus partly allowed. Disallowance out of motor car expenses and depreciation at the rate of 33.3% as against the claim of the assessee that the same be restricted to 25% - Held that:- The disallowance at the rate of 25% of the motor car expenses and also out of the claim of depreciation is a reasonable disallowance which assessee herself has offered. We accordingly restrict the disallowance in relation to motor car expenses and depreciation to the extent of 25% instead of 33.3% made by the lower authorities. - Decided in favour of assessee in part.
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