Disallowance under Section 14A of the Act computed in
accordance with Rule 8D read with Sections 14A 2 & 3 of the
Act
The Appellant ... vide the
Assessment Order framed under Section 143(3) of the Act, computed
the disallowance under Section 14A of the Act in accordance with
Officer had sent show cause notice as
to why the disallowance under section 14A would not be
made in this case. According to the assessee ... holding that
disallowance of 1% of interest expenses made for earning
exempt income by the Assessing Officer and disallowance
made under section 14A
borrowed fund. Under the facts and
circumstances of the case, disallowance of expenditure is
called for under the provisions of section 14A ... under section 80M is not well founded.
The basis on which we arrived at those conclusions would
apply equally to a case under section 14A
under
section 10(34) of the Act. For earning the exempt income, the assessee had offered
disallowance of Rs. 10,00,000/- under section 14A ... form part of the total income. Under the circumstances, the
computation of the disallowances under section 14A read with rule 8D(2)(iiI0, which
Bank Ltd. (supra) held
that while considering disallowance under Section 36(1)(iii) the application of
Section 14A of the Act would apply. Considering ... adhoc disallowance u/s 14A of the Act.
10. Ground No.1 relates to disallowance u/s 14A of the Act (normal disallowance).
We have
final assessment order passed under Sec.143(3) r.w.s.
144C(13), dated 30.01.2015, restricted the disallowance under Sec.14A to the extent ... assessment order passed under Sec. 144C(1) r.w.s 143(3), dated
18.03.2014, had worked out the disallowance under Sec.14A
made to the book profits computed under section 115JB in
respect of disallowance made under section 14A as per Rule 8D.
2. Taxability of receipt ... year under consideration. The
assessee has not made any disallowance on account of administrative
expenses in the working of disallowance under section 14A
UNDER SEC. 14A:
The CIT(A) after deliberating on the contentions of the assessee, therein
observed that the A.O had as per Sec. 14A ... aforesaid disallowance
of Rs. 32,41,761/- under Sec. 14A r.w Rule 8D, as under:-
(i).Disallowance of interest expenditure [Rule
disallowance under section 14A :
2.1 Without prejudice to above, in case if section 14A is held to be applicable,
the disallowance in relation ... under section
10(34) / (35) of the Act amounting to Rs.3,56,74,725/-. The assessee had not
disallowed any expenditure under section 14A
disallowance under Sec. 14A in
the hands of the assessee under Sec. 14A r.w. Rule 8D, as under:-
Particulars Opening Balance (as on Closing ... respect to the
correctness of the disallowance offered by the assessee; (ii) that the
disallowance under Sec. 14A r.w. Rule 8D could not exceed
