TMI Blog2019 (8) TMI 978X X X X Extracts X X X X X X X X Extracts X X X X ..... herefore, we are of the view that no interest expenditure should be disallowed u/s. 14A r.w. rule 8D in the case of the assessee. Regarding administrative expenditure, we are of the view that no exempt income can be earned without incurring any administrative expenditure, therefore, we restore this issue of computing administrative expenditure incurred for earning exempt income to the file of assessing officer and direct the assessing officer to compute administrative expenditure @ 0.5% of investment from which the assessee has earned the tax free income. Therefore, the appeal of the assessee is partly allowed. - ITA No. 2558/Ahd/2017 - - - Dated:- 27-3-2019 - Shri Amarjit Singh , Accountant Member And Ms. Madhumita Roy, Judic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve incurred administrative expenses such as documentation, salaries of employees, in relation to investment portfolio, stationary, computer etc. Therefore, the assessing officer has computed the disallowance as per provision of section 14A r.w.s. Rule 8D to the amount of s. 94,76,690/- and added to the total income of the assessee. 3. Aggrieved assessee has filed appeal before the ld. CIT(A). The ld. CIT(A) has confirmed the disallowance made by the assessing officer reiterating the same reason mentioned by the assessing officer. 4. During the course of appellate proceedings before us, the ld. counsel has submitted paper book containing information and submission made before the assessing o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee company was ₹ 44,01,43,494/- as against which the total investment made by the assessee was to the amount of ₹ 42,30,86,522/-. The relevant parts of the information about the interest free funds and investment made by the assessee are reproduced as under:- Particulars As at 31/03/2013 As at 30/11/2013 As at 31/03/2014 Capital + Reserves 23,16,75,312/- 23,16,75,312/- 44,01,43,494 Profit earned till date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee s own fund and considering the other judicial decisions referred by the assesssee, we are not inclined with the decision of ld. CIT(A) in sustaining the impugned addition made by the assessing officer without giving reason for its justification, therefore, we are of the view that no interest expenditure should be disallowed u/s. 14A r.w. rule 8D in the case of the assessee. However, regarding administrative expenditure, we are of the view that no exempt income can be earned without incurring any administrative expenditure, therefore, we restore this issue of computing administrative expenditure incurred for earning exempt income to the file of assessing officer and direct the assessing officer to compute administrative ..... X X X X Extracts X X X X X X X X Extracts X X X X
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