2014 (9) TMI 1111

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....E R Per Sanjay Garg, Judicial Member: The present appeal has been filed by the assessee agitating the disallowance of Rs. 10,51,475/- made by the lower authorities under section 14A read with rule 8D of the Income Tax Rules. 2. The brief facts of the case are that the Assessing Officer (hereinafter referred to as the AO) during assessment proceedings noticed that the assessee had received....

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....claimed in the profit and loss account and interest was separately disallowed at Rs. 4,42,191/- under rule 8D(ii) of the Income Tax Rules. Out of the balance amount of Rs. 7,31,006/-, the AO had made disallowance of Rs. 11,73,198/- which exceeded the total claim of expenditure. The ld. CIT(A) observed that since the assessee had earned dividend income so assessee might have incurred some expenses ....

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....r has earned income of Rs. 1,27,81,581/- as per the profit and loss account. After setting off of business loss of the previous years, the net income of the assessee had been computed at Rs. 1,16,12,455/- , against which, the assessee had claimed expenditure of Rs. 11,73,198/- only. Out of  which, the interest expenditure had been claimed at Rs. 4,42,191/- and administrative expenses of Rs. 7....

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....incurred interest expenditure for earning of exempt income. So far the remaining amount of Rs. 7,31,006/- on account of administrative expenses is concerned, it is too meager as compared to the taxable income of the assessee. However, keeping in view, the overall facts and circumstances of the case and also the fact that the assessee had earned dividend income, it might have incurred some expenses....