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2019 (9) TMI 255 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - no expenditure incurred to earn the dividend income - reasonable nexus between the expenditure disallowed and the dividend income received - HELD THAT:- Assessee has not at all incurred any expenditure to earn the dividend income and this being the factual position and not having been rebutted by the AO in any manner, the provisions of S.14A could not have been invoked. The disallowance was made by the AO by invoking provisions of S.14 A r/w Rule 8D of the Rules by alleging that the part of expenditure claimed by the assessee has been incurred for earning of tax-free income though the assessee had not incurred any expenses to earn tax free income. AO before making said addition has simply referred to the relevant provisions and judgment of Hon'ble Supreme Court in the case of CIT vs United General Trust Ltd. [1993 (2) TMI 96 - SC ORDER] which cannot be applied to the instant case as the facts of the present case are totally different from the above case. No merit in the disallowance so made U/s 14A - decided in favour of assessee
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