erred in confirming the
disallowance of Rs.24950657/- u/s 14A / Rule 8D of
the IT Rules, after giving credit of Rs.22997000/-
already disallowed ... Assessing
Officer asked the assessee to explain why the provisions
of section 14A r.w.r. 8D of the Income Tax Rules
proceeded with levy of penalty u/s 271(1)(c) on the
disallowance ofRs 5,55,241/- u/s 14A ... claim of wrong deduction under section 80IC , claim of currency
fluctuation, on disallowance of interest under section 14A , and claim of
deduction on the interest
Avon Cycles Limited,
Ludhiana, wherein the AO had invoked section 14A of the Act read
with Rule 8D of the Rules and apportioned the expenditure ... Avon Cycles Limited,
Ludhiana, wherein the AO had invoked section 14A of the Act read with
Rule 8D of the Rules and apportioned the expenditure
facts of
the case by making the provisions of Section 14A read with
Rule 8D applicable to the Appellant Company in a
mechanical manner ... pertains to
disallowance of expenses made by invoking the provisions
of section 14A of the Income Tax Act, 1961 (in short
made by invoking the provisions of
section 14A of the Income-tax Act, 1961, by simply relying on the submissions of the
assessee ... erred in confirming the disallowance of
Rs. 5,31,145/- u/s 14A being 10% of the dividend income
considering the
appellant's request for not making any disallowance
u/s 14A which was initially made by the appellant while
filing the return ... ground No.6, the assessee has agitated the
disallowance of expenditure u/s 14A of the Income Tax Act which was
initially made
free income was held to be disallowed under
section 14A of the Act by the ITAT, it should be followed in this year also. Since ... income therefrom is only incidental to its business, the
provisions of section 14A cannot be applied. In the case of State Bank of
Hyderabad versus
erred in deleting the
addition made without appreciating the provisions of
section 14A and without considering the specific
clarification issued in this regard ... contention of the assessee that in the absence of
dividend income, section 14A is not applicable relying upon the decision
of Special Bench
included in the total income as defined Under Section 2(45) . Therefore, provisions of Section 14A are clearly attracted in this case. It was accordingly ... include the income referred to in Section 80P(2)(d) . Therefore, the provisions of Section 14A inserted w.e.f. 1.4.1962 are clearly attracted
exempt income earned by the
assessee under the provision of section 14A of the
Act.
14. Briefly stated, the A.O. on noticing that ... disallowance under
section 14A of the Act with respect to interest
expenditure can be made. A s regards
