2016 (7) TMI 1400

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....and the assessee  have filed the present appeals. 2.Assessee-company,engaged in the business of retailing a variety of household and consumer products,filed its return of income on 29.9.2008,declaring its income at Rs. 27.51 crores.The AO completed the assessment u/s.143(3) of the Act on 16.12.10 determining the income of the assessee  at Rs. 36.26 crores. ITA/2189/M/12: 3.Effective ....

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.... purchase the customer is given a monetary right in the form of rebate in the cost of goods that he will purchase at a future date.Thus, and when a right is given, the assessee incurs a liability which it has claimed as marketing expenditures. The assessee, based a historical data in a scientific manner, has estimated that only 50% of the reward points given are likely to be encashed by the cust....

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....isallowance made by the AO u/s.14A of the Act.During the assessment proceedings,the AO found that the assessee had made investments in shares, that the value of investment as on 31.3.2008was Rs. 80.72 crores,that it had claimed interest expenditure of Rs. 11. 23 crores.He directed the assessee to explain as to why disallowance u/s.14A r.w.Rule 8D of the Income tax Rules,(1962)should not be made.Th....

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....held that AO was authorised to make reasonable disallowance u/s.14A by making an estimate of attributable expenditure,that distinction between the investments out of the borrowed funds and own funds had been taken away by Rule 8D of the Rules.Finally,he upheld the order of the AO. 6.Before us, the Authorised Representative (AR) argued that assessee  had not claimed any expenditure,that no ex....