2016 (10) TMI 1253

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....he appeal filed by the assessee is directed against the order dated 26.12.2014 passed by learned CIT(A)-6, Mumbai and it relates to A.Y. 2011-12. 2. The solitary issue urged in this appeal relates to disallowance made u/s. 14A of the Act. 3. Learned AR submitted that the Assessing Officer has made disallowance of Rs. 1.09 crores under Rule 8D(2)(iii) of the I.T. Rules as against disallowance....

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....ince the same has suffered taxation in the hands of company. Accordingly, learned AR submitted that he does not have any objection in setting aside this matter to the file of the AO and further prayed that suitable direction may be issued to the Assessing Officer to consider various contentions of the assessee. 4. On the contrary, learned Departmental Representative submitted that the income ea....

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.... be computed as per the formula provided in Rule 8D. However, the disallowance worked out under Rule 8D cannot exceed the total expenditure claimed by the assessee which can be apportioned to the exempt income. Thus we set aside this issue to the record of AO for the limited purpose of computing the total expenditure incurred by the assessee for the composite/indivisible activities in which taxabl....