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TMI Blog2015 (7) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... e Respondent : Sh. P. Radhakrishnan, JCIT ORDER PER N.R.S. GANESAN, JUDICIAL MEMBER: This appeal of the assessee is directed against the order of Commissioner of Income Tax (Appeals)-I, Madurai, dated 18.09.2014. 2. The first issue arises for consideration is with regard to expenditure incurred by the assessee on education of the children of the Directors. 3. Sh.S.A. Balasubramanyan, the Ld.c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve, submitted that admittedly the children of the Directors were sent to foreign for education and the expenditures were incurred by the assessee-company. According to the Ld. D.R., it is liability of the parents to educate their children. It is not the business expenditure of the company. Whether their grandchildren or children, the Directors have to educate them by their own income. No business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ility of the parents/ grandparents to give education to their children/grandchildren. No business purpose is going to be served to the assessee by incurring expenditure on the foreign education of the children and grandchildren of the Directors. Merely because the company was in existence for decades, the law laid down by the jurisdictional High Court in RKKR Steels P. Ltd. (supra) and in K. Subra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gard to accounts of the assessee. According to the Ld. counsel, it is the statutory obligation on the part of the Assessing Officer to record his satisfaction with regard to correctness of the claim on the basis of the accounts. Since the satisfaction was not recorded, according to the Ld. counsel, the disallowance made by the Assessing Officer is not justified. 8. On the contrary, Sh. P. Radhakr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... laim of the assessee on the basis of the books of account. Therefore, it would not be correct to say that the Assessing Officer is not satisfied with the correctness of the account. Rule 8D came into operation by Finance Act, 2009, which is mandatory for computation of disallowance under Section 14A of the Act. Therefore, this Tribunal do not find any reason to interfere with the order of the CIT( ..... X X X X Extracts X X X X X X X X Extracts X X X X
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