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2021 (1) TMI 734 - AT - Income TaxDisallowance u/s.14A r.w.r. 8D - Suo moto disallowance by assessee - AR submitted that the AO had made the impugned disallowance in terms of provision of Rule 8D(2) (iii), which was incorrect because there was no opening and closing balance of investments in the assessee's books on the first day and the last day of the year under consideration - HELD THAT:- We note that the AO has mentioned that the assessee has suo motu disallowed as disallowance u/s. 14A of the Act. Although, AR has argued that no such suo motu disallowance was made by the assessee in its computation of income, for want of evidences we cannot look into the issue at this juncture. Considering the smallness of the amount and also the alternate plea of the Ld. Authorized Representative on overall facts of the case, we direct that the disallowance be restricted to ₹ 67,853/- i.e. the amount of dividend earned by the assessee during the year under consideration. Appeal of the assessee stands partly allowed.
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