TaxTMI 
TaxTMI 
2019 (7) TMI 1494
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....ncerning A.Y. 2012-13. 2. In the captioned appeal, the assessee is aggrieved by the disallowance of Rs. 11,48,205/- sustained by the CIT(A) towards administrative expenses attributable to exempt income while computing the taxable income under the normal provisions of the Act. Similarly, the assessee is also aggrieved by the adjustment of the aforesaid amount of disallowance carried out under s. 14A while computing book profits under s. 115JB of the Act. 3. When the matter was called for hearing, the Ld. AR for the assessee submitted that assessee has earned dividend income of Rs. 29,30,083/- during the year which was claimed as exempt on investment held by it amounting to Rs. 29,82,54,378/- in its balance sheet. The Ld. AR submitted that ....
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....m formula prescribed in the statute by way of Rule 8D(2)(iii) of the Rules. Such disallowance according to DR, therefore, should not be tinkered. 5. We have carefully considered the rival submissions. We note that assessee has claimed exempt income of Rs. 29,30,083/- only. The assessee was holding investment to the tune of Rs. 27.24 crores in the earlier year which has increased to Rs. 29.82 crores during the year. The assessee has made a suo moto disallowance of Rs. 66,180/- being 10% of the amount paid to a professional dedicated for monitoring investments. Thus, a basis has been provided by the assessee for suo moto disallowance. In such circumstances, on a broader consideration, we note that where the investments were largely made in ....