TMI Blog2018 (1) TMI 1299X X X X Extracts X X X X X X X X Extracts X X X X ..... for earning the said income. After considering the details of Schedule 19, we are of the opinion that the expenditure incurred by the assessee during the year was not related to earning of tax free income. Provisions of section 14A can be invoked only when some expenditure is claimed against the exempt income. As in the case under consideration the AO /FAA had not specified the items of expensed i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome at Rs. (-) 5, 40, 77, 445/- 2. Effective ground of appeal First ground of appeal is about confirming the addition of ₹ 31. 57 lakhs made by the AO u/s. 14A r.w.r. 8D of the Income Tax Rules, 1962 (Rules). During the assessment proceedings the AO found that the assessee had earned dividend income of ₹ 3. 23 crores, that same had been claimed exempt u/s. 10(34) of the Act. He ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der of the AO, the assessee preferred an appeal before the First Appellate Authority (FAA) and made detailed submissions. After considering the available material, he held that the AO had duly discuss the reasons for disallowance, that he had applied his mind before invoking the provisions of section 14A, that in the earlier years the then FAA. s had dealt with the issue of making investment in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hearing before us the Authorised Representative (AR) stated that as per Schedule 19 the assessee had incurred total expenses of ₹ 56. 10 lakhs, that expenses incurred under the heads rates, taxes, legal and professional charges amounted to Rs. more than 55 lakhs, that the balance expenses were about 41, 000/-(approximately). The Departmental Representative (DR)supported the order of the FAA. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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