TMI Blog2021 (2) TMI 1298X X X X Extracts X X X X X X X X Extracts X X X X ..... nder consideration - HELD THAT:- The lower authorities without considering the submissions made in proper perspective had proceeded to make the disallowance. On perusal of the material it is clear that no borrowings were utilized for the purpose of making the investments which yielded the dividend income. The borrowings shown in the books of account were made for specific purpose. In the abse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt) dated 10.10.2017 for the assessment year 2012-13. 2. Briefly, the facts of the case are that the appellant is a firm engaged in the business of manufacturing of automotive components. The return of income for the assessment year 2012-13 was filed on 29.09.2012 declaring total income of Rs.32,61,90,370/-. Against the said return of income, the assessment was completed by the Assistant Com ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. Before us, it is submitted that the assessee made suo-motu disallowance of Rs.1,57,500/- towards expenditure incurred towards earning dividend income of Rs.31,50,000/-. It is submitted that the dividend income was received from Lumax Industries Limited in which the investments were made in the earlier years and it was also demonstrated before us that in the earlier year no borrowed fun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal relates to the computation of amount of disallowance u/s 14A of the Act. It is a matter of record that the assessee offered a suo-motu disallowance of Rs.1,57,500/- towards the expenditure to earn dividend income. It was specifically contended before the Assessing Officer and the ld. CIT(A) that no borrowed funds were utilized for the purpose of making the investments which yielded the divid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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