2013 (10) TMI 1001

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.... Per Shri Mukul Kr. Shrawat, Judicial Member :- This is an appeal at the behest of the Assessee which has emanated from the order of Learned CIT(Appeals)-XI, Ahmedabad dated 22/05/2009 and the substantive ground is Ground No.1(i); reproduced below:- 1(i) The Commissioner of Income-tax (Appeals) XI, Ahmedabad [hereinafter referred to as CIT(A)] erred in confirming that the action of Assessing Of....

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....be not enhanced to the extent of disallowance made during the course of order u/s.143(3) dated 25.11.2003, on account of interest expenses to the tune of Rs.2877262/- u/s.14A of the I.T. Act, 1961." 4. After detailed discussion, the assessee's contention was rejected by the Assessing Officer and the income was finally determined as under:- "In view of the above, the book profit of the assessee i....

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....respect of any allowance or disallowance made during the computation normal income can be considered for the computation of the book profit for the purpose of section 115JB of the I.T.Act. Although this observation was made by the Learned CIT(Appeals) in paragraph No. 2.3.1, but the view was taken in favour of the Revenue, therefore the assessee being aggrieved is now in appeal. With this brief ba....

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....ith the issue of expenditure relating to dividend income, a matter falling under Chapter III, it becomes clear on perusal of these two provisions that they are similar in nature. Clause (f) uses the words "expenditure relatable to any income", while s. 14A uses the words "expenditure incurred by the assessee in relation to income". These words have the same meaning. We may also add here that s. 14....