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2015 (9) TMI 1664 - AT - Income TaxDisallowance u/s 14A - mandation of “satisfaction” having regard to the accounts of the assessee about the claim of the assessee - HELD THAT:- For making disallowance u/s 14A, the condition precedent is that the conditions laid down in sub-section (2) and sub-section (3) of section 14A has to be mandatorily fulfilled. If such conditions are not satisfied, then no disallowance u/s 14A can be triggered. Here in this case, not only from the accounts of the assessee but also looking to the nature of expenditure incurred and nature of investments standing in the Balance sheet, it cannot be held that any disallowance u/s 14A is called for. Nowhere the AO has given his “satisfaction” having regard to the accounts of the assessee about the claim of the assessee, that no expenditure has been incurred, which can be said to be attributable for making investment capable of earring exempt income or has yielded the exempt income is false or incorrect. Accordingly, on these facts we hold that no disallowance u/s 14A is called for
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