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2023 (7) TMI 376 - ITAT AHMEDABADDisallowance of other expenses u/s 14A r.w.r. 8D - whether assessee has not incurred any expenditure for earning exempt income? - appellant submits that the assessee has offered during assessment proceedings Rs. 45,000 for disallowance but AO has added Rs. 30,63,380 instead of Rs. 45,000 offered meaning by even if such expenses are disallowable than such expenses should not exceed Rs. 45,000. It is 0.5% of the average investment as per Rule 8D is not disallowable. HELD THAT:- Tribunal observed that involvement of top executives and use of other business office equipment like compute etc. and office premises in respect of investment activities cannot be ruled out. Therefore, the Tribunal in A.Y. 2013-14 restricted the disallowance under administrative expenditure to the amount of Rs. 4,00,000/-. At the time of hearing it appears that the assessee has made investment of Rs. 102.72 crore and profit for the year was Rs. 28.38 crore. The interest expenditure was Rs. 44.38 lakhs and therefore, in the present case also the calculation of Rs. 4,37,612/- is justifiable under administrative expenditure. Therefore, the appeal of the assessee is partly allowed.
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