TMI Blog2018 (10) TMI 867X X X X Extracts X X X X X X X X Extracts X X X X ..... We would clarify that the Assessing Officer while examining the question of disallowance under Section 14A would take into consideration all contentions and pleas of the appellant-assessee. Both the Assessing Officer and the appellant-assessee are bound by the ratio in Godrej and Boyce Manufacturing Company Ltd. (2017 (5) TMI 403 - SUPREME COURT OF INDIA) and Maxopp Investment Ltd. [2018 (3) T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Act, 1961 is a stale issue, which has already been answered in several cases including Godrej and Boyce Manufacturing Company Ltd. versus Deputy Commissioner of Income Tax, Mumbai and Another, (2017) 7 SCC 421 and in Civil Appeal Nos. 104-109 of 2015, Maxopp Investment Ltd. versus Commissioner of Income Tax decided on 12th February, 2018 . This argument has to be rejected. 3. On ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nection with the Head Office . Therefore in our considered opinion and relying on the case law cited by the assessee in the case of Maxopp (Supra), we are of the opinion that the Expenditure incurred only at Head office , which may have direct or indirect relationship for earning the exempt income should be considered for disallowance under section 14A of the Act. We, therefore think it fit in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee has been accepted. Tribunal has directed that only expenditure incurred at the head office would be taken into consideration. 6. During the course of hearing, on a question being put, learned counsel for the appellant-assessee has accepted that no self disallowance under Section 14A was made, though the appellant-assessee had earned dividend income of ₹ 2,85,43,064/-. 7. Appellant-a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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