TaxTMI 
TaxTMI 
2017 (2) TMI 641
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....(in short 'the Act'). 2. The appellant before us is a company incorporated under the provisions of Companies Act, 1956 and is, inter-alia, engaged in the business of financial services and investment consultancy. Insofar as the first issue in this appeal is concerned, the same relates to the disallowance made by the Assessing Officer u/s 14A of the Act of Rs. 18,62,864/- as against an amount of Rs. 72,371/- offered by the assessee. In this context, the relevant facts are that the assessee had earned exempt income of Rs. 2,37,46,587/- comprising of dividend of Rs. 29,00,000/- on preference shares of subsidiary company and the balance of Rs. 2,08,46,587/- from mutual fund units. The Assessing Officer show-caused the assessee as to why the ex....
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....ot applicable for the instant assessment year, yet the disallowance computed in terms of the said rule can be said to be a reasonable disallowance. 5. In our considered opinion, the Assessing Officer is clearly in error in computing the disallowance u/s 14A of the Act on the basis of Rule 8D of the Rules given the fact that the said rule is not applicable for the assessment year under consideration, as held by the Hon'ble Bombay High Court in the case of Godrej Boyce Mfg Co. (supra). Nevertheless, considering that the assessee has itself asserted that certain expenditure was incurred in relation to such exempt income, it would be in the fairness of things that a reasonable estimate be made of such expenditure. In order to arrive at suc....
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....he facts in relation to the said dispute can be understood as follows. The assessee-company is engaged in the business of investment banking which, inter-alia, involves advising various corporate clients for raising funds from international and domestic capital markets, financial restructuring, mergers & acquisitions, etc. In order to maintain appropriate quality level of its services, assessee is required to render professional advice on the prevailing market conditions. For the said purpose, assessee was required to have an in-house mechanism by which its personnel are updated on the developments in finance and investment climate available for opportunities. For this purpose, assessee incurred expenditure on research. To meet its research....
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....hat it is not necessary that the benefits of various reports generated by the research department would have a useful life of more than one year. Rather, it is pointed out that such research reports may have a very short life, e.g., daily morning reports are useful for only a day and similarly, quarterly and annual analysis of financial performance of an industry or corporate will become outdated as soon as the next financial year starts. The learned representative for the assessee pointed out that all these facts were brought out before the lower authorities, which are duly reproduced by them in their respective orders, but the same have not been properly appreciated. 10. On the other hand, the ld. DR has reiterated the stand of lower aut....