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2015 (4) TMI 1248 - AT - Income TaxDisallowance u/s 14A with reference to investment in partnership firm - Held that:- Assessee has bifurcated the expenses relating to various branches which cannot be considered at all for the earning of the exempt income, which has been worked out at 1,16,01,123. Out of the balance amount, expenditure like godown rent and warehousing charges, other trading expenses insurance, foreign following travelling, business promotion etc. aggregating to ₹ 1.15 crores cannot be considered as expenditure incurred for the purpose of earning exempt income. The balance expenditure comes to 2.59 crores and if salary cost of approximately 2.12 crores is added then the same comes to ₹ 4.71 crores. If from the total expenditure of ₹ 4.71 crores, the assessee itself has disallowed ₹ 1,65,43,645/-, then definitely it can be held to be reasonable attribution for the purpose of disallowance u/s 14A. Thus, the disallowance made by the AO over and above the disallowance and confirmed by the Ld. CIT(A) is deleted and accordingly, the order of the Ld. CIT(A) on this score is reversed. - Decided in favour of assessee.
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