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2015 (6) TMI 993 - AT - Income TaxDisallowance u/s. 14A - CIT(A) deleted the addition - Held that - The undisputed fact is that the investments have been made out of own funds and no borrowed fund was utilized. It is also undisputed fact that in both the years under consideration the assessee has disallowed suo motu fees paid to the portfolio manager. It is also an admitted fact that the Assessing Officer has nowhere recorded his dissatisfaction on the claim of expenditure attributable to the disallowance u/s. 14A made by the assessee. We therefore decline to interfere with the findings of the Ld. CIT(A). Allowable expenditure u/s 37 - Held that - Religious expenditure cannot be considered at par with expenditure on social cause. The undisputed fact is that in guise of advertisement expenditure the assessee has incurred expenditure towards renovation of Bandeshwar temple. This expenditure cannot be considered having been incurred towards corporate social responsibility. In our considered opinion only expenditure incurred towards discharge of corporate social responsibility can be considered as allowable u/s. 37(1) of the Act.
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