Total Turnover also for
the purposes of computing the deduction under section 10A of the Act."
20. Before us, both the parties pointed ... Assessing Officer in
disallowing expenditure u/s 14A of the Act aggregating to Rs. 4,53,507/-
towards the earning of dividend income, by applying
made in the
Assessment order u/s. 143(3)
Income as per Order u/s. 143(3) 3,598,507
Less: Returned income
against the deletion of penalty of
`6,27,507 imposed by the Assessing Officer u/s 271(1)(c) of the Act
in relation
being depository charges and
Rs.24,355/- being miscellaneous expenses under section 14A of the
Act as these expenses did not relate to earning taxable ... which the interest
component is ` 7,96,507. From the balance, the assessee has itself
disallowed ` 23,35,000 towards donation. Then again
pertains to disallowance computed by the AO at
Rs. 78,252/- u/s 14A.
13. The facts are that the assessee during the current year ... should be Rs. 64,507). In effect, the
CIT(A) sustained the disallowance u/s 14A at Rs. 64,406/-.
15. Aggrieved, the assessee
assessment framed under
section 143(3), the AO made a further disallowance of Rs.14,26,507/- and added
the sum to the total income ... material on
record. It is noted that the question of making disallowance u/s 14A is no more res
integra in view of the judgment
Deepak Agarwal, Mumbai vs Assessee on 28 February, 2013
IN THE INCOME TAX APPELLATE TRIBUNAL
Syngenta India Ltd, Pune vs Assessee on 20 June, 2013
आयकर अपील य अ धकरण
that sense,
assessee is an ultimate beneficiary within the meaning of section 2(22)(e) of the Act.
4
In the process, AO rejected ... towards share application money constitutes loan or advances within the meaning of
section 2(22)(e) of the Act, AO relied on various decisions which
cure
the initial defect, as has been pointed out that the notice u/s 143(2)
was not served on the assessee. In our considered ... considered view that the penalty initiated and levied u/s 271(1)(c) ,
on illegal foundation, does not deserve to survive. On merits, as well
