2014 (6) TMI 929

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g to the assessment years 2003-2004 and 2002-2003 respectively the following substantial questions of law arise for consideration: In ITA No.382/2010, "Whether the tribunal was correct in holding that no expenditure that no expenditure can be attributed to the exempted income of Rs. 227,14,06,572/- earned by the assesse by reversing the finding of the Assessing Officer who had estimated the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....en no expenditure is incurred by an assessee in earning the dividend income, no national expenditure could could be deducted from the said income. Though benefit u/s. 80m is granted on the net income, when no expenditure is incurred in earning the dividend income, the gross income would become the net income. Thus, there is no scope for any estimation being made or any amount being deducted as not....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....these develpoments in deciding whether any expenditure is incurred in earning the said income. The discussion by the assessing authority clearly demonstrates these aspects has not been taken note of and the notional expenditure is calculated pre modernization. Therefore, in the light of the aforesaid Judgement, when the assessee has not incurred any expenditure for realizing this income, the quest....