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2024 (2) TMI 1228 - AT - Income TaxDisallowance u/s 14A - Expenditure incurred on earning exempt income - exempt income earned or not? - HELD THAT:-There was no exempt income was earned during the year, THUS in the absence of exempt income, no disallowance u/s 14A can be made, we find merit on the Ground No. 1. MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - HELD THAT:- As in the case of CIT Vs. ICIC Venture Funds Management Company Ltd. [2015 (1) TMI 1504 - KARNATAKA HIGH COURT] held that lease equalization charges are not covered under any of the Clauses Explanation to Section 115JA (2). Also see M/S. MGF INDIA LTD. [2018 (2) TMI 1535 - DELHI HIGH COURT] Lease equalization charges are not to be treated as adjustments needing to be added back while computing book profits, u/s 115JA on account of explanation 1, we allow the Ground No. 2.
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