2013 (5) TMI 117

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....al, AM : These two cross appeals - one by the assessee and the other by the Revenue - arise out of the order passed by the Commissioner of Income-tax (Appeals) on 14.05.2010 in relation to the assessment year 2007-2008. 2. The only issue raised by the assessee in its appeal is computation of disallowance u/s 14A read with Rule 8D. 3. We have heard the rival submissions and perused the rel....

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.... the amount of disallowance u/s 14A and disallowance of Rs.10.06 lakh of prior period expenses while computing profits u/s 115JB of the Act. 5. We have heard the rival submissions and perused the relevant material on record. It is observed that the Assessing Officer added the amount disallowed by him u/s 14A to the tune of Rs.78.84 lakh to the book profit computed u/s 115JB. The learned CIT(A) ....

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....[(2009) 32 SOT 101 (Del.)] laying down similar proposition. The learned AR has also placed on record one more order passed by the Delhi Bench in the case of Quippo Telecom Infrastructure Ltd. v. ACIT in ITA No.4931/Del/2010 in which it has been reiterated that the amount disallowed u/s 14A cannot be considered while computing book profit u/s 115JB of the Act. No contrary decision has been brought ....