2018 (2) TMI 1215

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.... (PER : HONOURABLE Mr. JUSTICE AKIL KURESHI) Revenue has filed this Appeal challenging the judgment and order dated 31st May 2017, raising the following questions for our consideration : [A] "Whether the Appellate Tribunal has erred in law and on facts by deleting the addition of Rs. 88,231,450/= made under Section 14A of the Act on account of expenses incurred towards the exempted in....

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....Section 14A of the Act ought to be invoked. He accordingly disallowed certain interest expenditure as well as inflated the administrative expenditure shown by the assessee for earning such tax exempt income. The Tribunal found that the assessee had surplus tax free funds, and therefore, there was no question of disallowance of any interest income. We are however concerned with the latter portio....

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....g Officer attribute administrative expenses for earning tax free income in excess of the total administrative expenditure incurred by the assessee. If it is a case where Assessing Officer disputes, question and disallow the very declaration of the assessee regarding total administrative expenditure, the issue can be somewhat different. Nevertheless, when the Assessing Officer has in the present ca....