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2015 (11) TMI 1207 - AT - Income TaxDisallowance u/s 14A - Held that:- In the case of assessee no bank borrowings, no bank over-draft/deposits and nor any interest expenditure has been claimed by the assessee in the computation of total income and the port-folio management was looked after by the Director. There was sufficient source of funds which was required to make fresh investment in shares and mutual funds during the year and nothing contrary to the above facts have been brought on record by the Revenue, and in these circumstances, we find it justified to delete the addition made by the AO in regard to disallowance made u/s 14A - Decided in favour of assessee. Disallowance from rental income on estimated ad hoc basis - Held that:- Assessee has earned rental income and has shown the same under the head income from house property, claimed 30% deduction for repairs allowable under section 24. Assessee’s books are audited and it is a limited company and working since 94 years. AO in his assessment order has not been able to bring any specific material on record to prove that expenses shown in the profit and loss a/c were in any way attributable specifically for earning rental income. But has made ad hoc disallowance of ₹ 1,50,000/- deeming that there has been some nexus of some portion of the expenses incurred by the assessee company during the year to earn rental income. Therefore, in view of the above and for the lack of proper working to show that expenses specifically for earning rental income having claimed as expenditure under the head business or profession, we are of the view that AO was not justified in making such ad hoc disallowance. - Decided in favour of assessee.
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