TaxTMI 
TaxTMI 
2017 (2) TMI 991
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....erred in deleting the disallowance made under section 14A of the Income Tax Act, 1961 ["Act" in short]. 2. Brief facts of the case are that the assessee has filed its return of income on 28.03.2013 declaring total income at Rs..1,26,71,670/- and revised the same on an income of Rs..1,19,44,690/- and further revised the return on 25.02.2014 declaring income of Rs..97,36,520/-. The case of the assessee was selected for scrutiny and notice under section 143(2) of the Act dated 23.09.2013 was issued and duly served on the assessee. After considering the submissions of the assessee, the assessment was completed under section 143(3) of the Act by determining total income of the assessee at Rs..1,75,03,473/- after making various disallowances. 3....
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....year. Most of the investments are in subsidiary companies. Since any investment in a company is capable of earning dividend, the assessee was asked to explain as to why disallowance under section 14A of the Act should not be made. Vide his reply dated 18.11.2014, the AR of the assessee has submitted that the assessee did not earn any exempt income and also did not incur any direct expenditure to earn the exempt income and moreover no indirect/common interest expenses have been incurred/claimed. It was also submitted that the expenditure on investment in subsidiary was out of commercial expediency and hence no expenditure can be disallowed. However, by applying the provisions of Rule 8D, the Assessing Officer has estimated the expenses and d....
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....0/-. The contention of the assessee is that the assessee has earned dividend income of Rs. 4.6 Lakhs which is fully exempt u/s. 10(34) of the Act. The assessee has made voluntarily disallowance of Rs. 45,927/- u/s. 14A. The assessee has made fresh investments to the tune of Rs. 9.4 Crores during the year. The Assessing Officer held that the investments have been made from the fresh secured loans obtained during the year by the assessee. The CIT(Appeals) after going through the submissions made by the parties has come to the conclusion that the assessee has made investments from its own funds except for the short term investments made in HDFC Cash Management Fund and DSPML Cash Plus Fund in respect of which the amounts were invested from int....