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2020 (8) TMI 16 - AT - Income TaxDisallowance u/s. 14A on account of administrative expenses - HELD THAT:- As relying on M/S. MAZDA LIMITED [2020 (4) TMI 251 - ITAT AHMEDABAD] we find it justified in restricting the disallowance of administrative expenses on ad-hoc basis at 1% of the exempt income as per Clause (f) to Explanation-1 of Sec. 115JB of the Act. The order, is, passed accordingly. This ground of appeal is, thus, partly allowed. Addition to the book profit under Section 115JB on account of disallowance of the same amount u/s 14A - HELD THAT:- As relying on JAYSHREE TEA & INDUSTRIES LTD. [2014 (11) TMI 1169 - CALCUTTA HIGH COURT] AND VIREET INVESTMENT (P.) LTD. [2017 (6) TMI 1124 - ITAT DELHI] ad-hoc disallowance at 1% of the exempt income under Clause (f) to Explanation 1 of Section 115JB of the Act would be justiciable. Hence, we limit the disallowance of ad-hoc basis at 1% of the exempt income as per Clause (f) to Explanation 1 of Section 115JB of the Act. This ground of appeal, thus, is partly allowed.
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