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TMI Blog2018 (8) TMI 1485X X X X Extracts X X X X X X X X Extracts X X X X ..... cted against the order of Commissioner of Income Tax (Appeals)-5, Pune dated 18-03-2016 for the assessment year 2010-11. The solitary issue raised by the assessee in appeal is against confirming of disallowance Rs. 10,92,618/- u/s. 14A of the Act r.w. Rule 8D(2)(iii) of the Income Tax Rules, 1962. 2. Shri Krishna Gujrathi appearing on behalf of the assessee submitted that the assessee is a partne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner of Income Tax (Appeals) that disallowance u/s. 14A cannot exceed the actual expenditure incurred for earning exempt income. The ld. AR pointed that indirect expenditure incurred by the assessee and debited to P & L Account is to the tune of Rs. 25,78,927/-. Out of the aforesaid expenditure, expenditure to the tune of Rs. 22,43,620/- is unrelated to earning of exempt income. Thus, disallowanc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nfirming of disallowance of Rs. 10,92,618/- u/s. 14A r.w. Rule 8D(2)(iii). The short contention of the assessee is that the disallowance u/s. 14A cannot be made beyond the expenditure debited to P & L account in relation to earning of exempt income. The ld. AR has referred to the P & L account at page 32 of the paper book and the details of Indirect Expenditure at page 34 of the paper book. The to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f expenditure debited to P & L account. Similar view has been taken in the case of Income Tax Officer Vs. Pioneer Radio Training Services Pvt. Ltd. (supra) and in the case of M/s. Search Enviro Ltd. Vs. ACIT (supra). In light of the decisions referred above, in principle we agree with the proposition mooted by the ld. AR. However, we are of considered view that the indirect expenditure referred to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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