TMI Blog2014 (6) TMI 929X X X X Extracts X X X X X X X X Extracts X X X X ..... iture is calculated pre modernization. When the assessee has not incurred any expenditure for realizing this income, the question of holding that 2% of the gross total income is an expenditure and that has to be added back to the income is unsustainable in law. - Decided in favour of assessee. - ITA No.382/2010, ITA No. 381/2010 - - - Dated:- 2-6-2014 - N.Kumar And B. Manohar JJ. For the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7; 275,52,21,268/- earned by the assesse by reversing the finding of the Assessing Officer who had estimated the expense at ₹ 9.45 Crores which was reduced to 2% by the Appellate Commissioner in accordance with section 14A of the Act? 2. This court had no occasion to consider the very same substantial question of law in the case of very same assesse in ITA No.1396/2006 and other connecte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s.10 (23G) of the Act. In other words, the persons with whom the amounts are invested by the assesse are creiditing the aforesaid amount to the asssessee s account by way of a bank transfer. Therefore,no human agency is involved in collecting these dividends and interest for which the assesse has to incur any expenditure. This is the consequences of computerization, online transaction through NEFT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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