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2019 (2) TMI 1069 - AT - Income TaxDisallowance u/s 14A - Held that:- Disallowance against average investments which have actually yielded exempt income during the impugned AY works out to ₹ 0.84 Lacs which is less than suo-moto disallowance as offered by the assessee. It is further noted that the assessee has debited various expenditure aggregating to ₹ 59.53 Lacs in the profit & loss account. The expenditure under the head commission & depreciation aggregate to ₹ 54.24 Lacs whereas the balance expenditure under other heads aggregate to ₹ 5.29 Lacs. The commission and depreciation have no nexus with earning of exempt income whereas out of balance expenditure of ₹ 5.29 Lacs, the assessee has already offered suo-moto expenditure of ₹ 2.34 Lacs. The same, in our opinion, was more than sufficient to cover up the requisite disallowance. Therefore, on the facts and circumstances of the case, the additional disallowance of ₹ 8.95 Lacs as made by Ld. AO could not be sustained. By deleting the same, we allow the appeal.
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