offered by the assessee as required by the
provisions of section 14A of the Act. In this regard, it was submitted on behalf ... income which is exempt u/s. 10(34) of the Act and how the
computation for disallowance u/s. 14A
deleting the
addition of Rs.297,38,902/- made under section 14A of the Act. The
facts set out by the Assessing Officer on this ... under section 115JB of
Rs.72,71,14,332/-. While doing so, the assessing officer made the
following disallowances:
i. Addition under section 14A
proceeded
with and on the basis of the methodology contemplated under Sec. 14A r.w
Rule 8D, therein worked out a disallowance aggregating ... that
application of provisions of sub-section (2) & (3) of Section 14A and Rule 8D
is not automatic in each and every case where
raised in assessee‟s appeal
is regarding disallowance made under section 14A of the Act by applying
provisions of rule 8D of the Income ... income earned and the expenditure incurred as per the
provisions of section 14A r/w rule 8D. In reply, the assessee submitted that
the expenditure
Appellant‟s o wn case for earlier years.
3. Disallowance under section 14A of the Act on account of exempt interest earned on
Pass Through ... disallowing a sum of INR 2,25,21,366 under section
14A of the Act read with Rule 8D of the Income-tax Rules („Rules
Disallowance under section 40(a)(ia) of the I.T.Act -
Rs.4,41,36,799;
* Disallowance under section 14A ... correct
amount of relief under section 10A of the Act for each unit.
7. Disallowance under section 14A
order of the AO in part by
sustaining the disallowance under section 14A of the Act instead of deleting the
hundred percent addition made ... connection with such income
in the manner as provided under section 14A of the Act.
6.1 As per the assessing officer, the assessee has borrowed
addition made of Rs.13,21,44,035/-.
Ground Ill :Disallowance u/s 14A
1. On the facts and in the circumstances of the case ... Appellant therefore prays that AO be directed to restrict the disallowance U/s 14A at
Rs.Nil/- being to the amount of exempt income earned
computation of Minimum Alternative Tax [MAT] u/s 115JB. So
far as the adjustment of disallowance u/s 14A in computation of book profit
... purpose of Section 115JB . Resultantly, Ground No. 6
stands allowed.
5.5 So far as the quantum disallowance u/s 14A as raised in Ground
Numbers
Ganesan,
Managing Director as well as confirmation of disallowance under section
14A r.w. Rule 8D.
2 I.T.A. No. 1177/Chny ... widened under
section 14 A."
35) The Delhi High Court, therefore, correctly observed that prior to
introduction of Section 14A
