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2020 (3) TMI 387 - AT - Income TaxDisallowance u/s 14A - suo moto disallowance by assessee - HELD THAT:- No exempt income is earned by the assessee during this year therefore, we direct the Assessing Officer to restrict the disallowance suo-moto offered by the assessee at ₹ 8,20,000/-. Addition on account of presumptive basis under section 5 on advances made by assessee to its subsidiaries - HELD THAT:- Assessee advanced the money to its subsidiary, which falls under the business expediency. Therefore, in the present case that the assessee advances to its subsidiary for business requirements, which may have impact on the objectives of the assessee for earning future revenue to the assessee. When it made in relation to advances. Though, it is another fact that the business of such nature did not materialized in positive outcome and the subsidiary had to close such business operation. The Hon’ble Supreme Court in S.A. Builders [2006 (12) TMI 82 - SUPREME COURT] held that whether expenditure may not have been incurred under any legal obligation, yet it is allowable as a business expenditure if it was incurred on grounds of commercial expediency. The case of the assessee is that the assessee has made advances to its subsidiary for business expediency. - Decided against revenue
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