s. Godrej Investments Pvt. Ltd.,
income. Without prejudice to the above submissions assessee also
submitted working of disallowance u/s. 14A ... authorities can
disallow interest expenditure after reducing the interest income earned by
the assessee for the purpose of disallowance u/s. 14A
declined to
admit the same. Resultantly, the disallowance u/s 14A that was revised by the assessee ... were
filed by the assessee with the DRP against the disallowance u/s 14A of Rs. 130,98,64,725/-
that was proposed
DIVIDEND DISALLOWANCE DISALLOWANCE Disallowance of 14A Disallowance of 14A
under Rule 8D(2) (iii),
YEARS INCOME (in Rs.) OFFERED BY THE UNDER 14A MADE ... Department's appeal wherein the issue under dispute
pertains to disallowance u/s 14A of the Act. The Assessing
Officer had made a disallowance
further submitted that the
disallowance made by the A.O u/s 14A in respect of the dividend income
earned on the shares held ... reconciliation of AIR data. Rs. 10,52,97,800/-
5. Disallowance u/s 14A r.w Rule 8D. Rs. 60,38,279/-
24. The assessee
u/s 14 A of the Act in its computation
of income. Observing, that the disallowance u/s 14A was not as per the
mechanism ... disallowance of interest expenditure u/s 36(1)(iii) of the
Act and not qua the disallowance under Sec. 14A of the Act. Also
being
further disallowance u/s 14A of the I.T. Act while calculating Book
Profit u/s 115JB of the I.T Act
Your Appellant ... deleting the addition u/s 14A of the
Income Tax Act, 1961 by ignoring the fact that the provisions of
Section 14A apply, even
u/s. 14A r.w.r. 8D in MAT computation hence
lowering the MAT credit. According to the assessee the disallowance
u/s.14A ... directed to recompute book profit u/s 115JB after excluding
disallowance u/s 14A . This ground of appeal is allowed. "
17. We heard
justified in deleting the disallowance made u/s 14A of Income Tax Act, 1961 read
with Rule 8D(iii) of Income Tax Rules ... upholding the
disallowance made u/s 14A amounting to Rs. 1,51,728/- in assessment made u/s
115JB of the Income Tax Act.
Grounds
earning it, being disallowance u/s
14A of the Act, be reduced from the book profits computed u/s ... while determining the
profit u/s.115JB of the Act after adjusting the expenses of disallowance made u/s 14A
computation of
book profit u/s 115JB , in respect of disallowances of expenditure u/s
14A of the Act, although, the issue has been covered ... made towards book profit computed u/s 115JB on account of
disallowance made u/s 14A for the purpose of computation of book profit
u
