TMI Blog2012 (3) TMI 421X X X X Extracts X X X X X X X X Extracts X X X X ..... was thus quite justified in deleting the interest disallowance. We have also noted that entire expenses incurred by the assessee have been offered for disallowance, and once that happen, nothing remains for further disallowance u/s. 14A. The disallowance under section 14A can come into play only out of expenses claimed for deduction and expenses have been claimed for deduct ion, there cannot be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 86,306/- under rule 8D(2)(ii ) being a part of total disallowance u/s. 14A since he opined in the instant case that there cannot be any interest expenditure left where interest income is more than interest expenditure. (2) That on the facts and circumstance s of the case, ld. CIT(A) erred in law in deleting the disallowance of ₹ 19,14,503/ - under rule 8D(2) (iii) being a part of total disal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0,64,547/ -, he disallowed ₹ 9,86,306/- by taking into account of average investments. The proportionate expenses as per Rule 8D(2)(iii ) were also computed at ₹ 19,14,503/-. Aggrieved, assessee carried the matter in appeal before the CIT(A). Learned CIT(A) noted that there was no interest expenditure, after setting off interest income earned, and, as such, the Assessing Officer was in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an be disallowed as attributable to earning tax free dividend. The CIT(A) was thus quite justified in deleting the interest disallowance. We have also noted that entire expenses incurred by the assessee have been offered for disallowance, and once that happen, nothing remains for further disallowance u/s. 14A. The disallowance under section 14A can come into play only out of expenses claimed for d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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