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2017 (11) TMI 1350 - AT - Income TaxDisallowance u/s. 14A - material to establish the direct nexus between the expenditure incurred and the income not forming part of total income - Held that:- We observe that during the impugned year, assessee has not made any fresh investment. The assessee had total net worth of ₹ 321.82 crores and total investment in subsidiaries is ₹ 113.16 crores, out of which 0.18 crores is in foreign subsidiaries and rest amount of ₹ 112.98 crores has been invested in Indian subsidiary companies. The dividend received from foreign subsidiary companies is taxable. It is evident from the record available before us that the assessee has not paid any interest for making investment in subsidiaries and no fresh investment has also been made during the year. The ld. CIT(A), after considering the submissions of the assessee and the order of the Assessing Officer has made good reasoned order in deleting the disallowance u/s. 14A of expenditure - Decided against revenue
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