TaxTMI 
TaxTMI 
2012 (3) TMI 421
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....sessing Officer has challenged correctness of learned Commissioner of Income Tax(Appeals)'s order dated 28th April, 2011, in the matter of assessment under sect ion 143(3) of the Income Tax Act, 1961 for the assessment year 2008-09, on the following grounds : - (1) That on the facts and circumstance s of the case, ld. CIT(A) erred in law in deleting the disallowance of Rs. 9,86,306/- under rule 8....
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....but offered only Rs. 1,11,521/ - for disallowance u/s. 14A on estimate basis. The Assessing Officer, however, observed that when assesese earns all its income from same establishment and composite fund of the company is utilized, expenses will have to allocate as per Rule 8D. Accordingly, out of total interest expenses debited to profit and loss account Rs. 10,64,547/ -, he disallowed Rs. 9,86,306....
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....val contentions, perused the material on record and duly considered factual matrix of the case as also the applicable legal posit ion. 4. As learned CIT(A) has rightly observed, once there is no net interest expenditure, as is the case before us - upon setting off interest credited to profit and loss account, no part of interest debited can be disallowed as attributable to earning tax free divide....