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of <h1>ITAT grants relief on disallowance under section 14A, 115JB, upholds late payment disallowance.</h1> <h3>M/s. Adani Properties Pvt. Ltd. Versus D.C.I.T, Cirle-1 (1) (1) Ahmedabad.</h3> M/s. Adani Properties Pvt. Ltd. Versus D.C.I.T, Cirle-1 (1) (1) Ahmedabad. - TMI Issues:1. Disallowance under section 14A read with Rule 8D2. Disallowance of late payment of employees' contribution to PF and ESI3. Addition while computing book profit under section 115JB of the IT ActIssue 1 - Disallowance under section 14A read with Rule 8D:The appellant contested the disallowance of Rs. 67,86,490 out of the total disallowance made by the Assessing Officer under section 14A read with Rule 8D. The AO found that the assessee earned dividend income claimed as exempt under section 10(34) but did not disallow corresponding expenses. The CIT (A) reduced the disallowance to Rs. 67,86,490, considering only expenses related to the dividend income. The ITAT referred to a previous year's decision where relief was granted on similar grounds. The ITAT allowed relief to the assessee in part, following the precedent.Issue 2 - Disallowance of late payment of employees' contribution to PF and ESI:The assessee's appeal against the disallowance of Rs. 80,870 for late payment of employees' contribution to PF and ESI was dismissed. The AR acknowledged that the issue was unfavorable based on a High Court ruling. The ITAT upheld the decision of the authorities, citing the relevant legal provisions and the High Court judgment.Issue 3 - Addition while computing book profit under section 115JB of the IT Act:Regarding the addition of Rs. 67,86,490 while computing income under section 115JB, the ITAT partially allowed relief to the assessee based on a previous decision in the assessee's favor. The ITAT noted similarities with a previous case and granted relief accordingly.In conclusion, the ITAT allowed the appeal in part, providing relief to the assessee on the issues of disallowance under section 14A read with Rule 8D and addition while computing book profit under section 115JB. However, the disallowance of late payment of employees' contribution to PF and ESI was upheld.
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