Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (9) TMI 1244 - AT - Income TaxAddition u/s 14A - Held that:- The investments have been classified by the assessee as Strategic investments, Stock–in-trade & investment in other Shares / Venture Capital Fund. The assessee has already offered suo-moto disallowance @0.5% against investment in other Shares / Venture Capital Fund and therefore, there is no dispute against this category of investment. The disallowance under dispute is against Strategic investments & Stock–in-trade. In the absence of adequate data before us, AO to compute disallowance @0.5% against Strategic investments & Stock–in-trade after excluding there-from those investments which have not yielded any exempt income during impugned AY or which were not, at all, capable of yielding any exempt income subject to a further condition that overall disallowance, in no case, shall exceed exempt income of ₹ 131.46 Lacs earned by the assessee during the impugned AY. This ground stand partly allowed in terms of our above order. Unexplained entries appearing in Annual Information Return [AIR] - Held that:- Assessee was unable to reconcile certain entries as appearing in Annual Information Return [AIR] and therefore, the same were added to the income of the assessee. The same, upon confirmation by Ld. first appellate authority, is under appeal before us. The Ld. Sr. Counsel submitted that keeping in view the voluminous nature of data, the same remained un-reconciled and a view may be taken. In the absence of complete factual matrix, we are unable to provide any relief to the assessee, in this regard. This ground stand dismissed.
|