TMI Blog2009 (12) TMI 617X X X X Extracts X X X X X X X X Extracts X X X X ..... wed by the Assessing Officer had been deleted Held that- . A perusal of the decision of the Punjab and Haryana High Court clearly shows that for the purpose of making a disallowance under section 14A, a finding of incurring the expenditure for earning the exempt income is absolutely necessary. Here in the present case, it is noticed that the Assessing Officer has not brought out any specific expen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arned Commissioner of Income-tax (Appeals) in deleting the disallowance made by invoking the provisions of section 14A on the ground that the management expenses attributable to the dividend income disallowed by the Assessing Officer had been deleted. 2. It was the submission by the learned Departmental representative that the assessee is an investment company and the assessee had received divid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Special Bench of the Income-tax Appellate Tribunal had been rendered in the case of ITO v. Daga Capital Management (P.) Ltd. [2009] 117 ITD 169 (Mum.). It was the submission that in view of the decision of the Special Bench of this Tribunal in the case of Daga Capital Management (P.) Ltd. referred to (supra) the order of the learned Commissioner of Income-tax (Appeals) was liable to be revers ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat in the course of assessment proceedings, the assessee had also been asked as to the details of expenses incurred in relation to the dividend income and the assessee had replied that no expenses had been incurred for the same. It was the submission that the decision of the Punjab and Haryana High Court in the case of Hero Cycles Ltd. (supra) was after the decision of the Special Bench in the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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