Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2017 (12) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (12) TMI 1592 - HC - Income TaxDisallowance u/s 14A - AO applied the formula indicated in Rule 8D (ii) & (iii) of the Income Tax Rules - CIT (A) granted partial relief after analysing the decision but upholding the rejection of the disallowance by the AO offered by the assessee. The ITAT in the impugned judgment granted complete relief to the assessee - Held that:- entire exempt income in the present case was purely incidental, consequent of the deployment of surplus funds for a part of the period. The findings of the CIT (A) clearly point to the fact that the assessee had utilised the entire borrowed funds for the purpose of setting up of its plan and undertaking the industrial activity. In these circumstances, the disallowance offered - of the entire exempt income - could not have been reasonably rejected. - Decided against the revenue.
|