2018 (6) TMI 1720

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....nt : Shri V. Vidhyadhar ORDER Per B.R. Baskaran, AM This appeal filed by the assessee is directed against the order dated 11.02.2016 passed by the CIT(A)-6, Mumbai and it relates to A.Y. 2012-13. 2. The issue urged in this appeal relates to disallowance of expenses relating to exempt income made under Section 14A of the Income Tax Act (hereinafter "the Act") and also disallowance made ....

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....ed a sum of Rs. 745.46 lakhs under Section 14A, the AO did not disturb the working made by the assessee. The AO also accepted the working of expenses relating to exempt income made by the assessee for computing books profit under Section 115JB of the Act. 4. In appellate proceedings the learned CIT(A) held that the amount worked out for disallowance under Section 14A of the Act has to be adopte....

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....e computed under Section 14A of the Act for the purpose of computing book profit under Section 115JB of the Act. 6. The learned A.R. placed reliance on the decision rendered by the Special Bench in the case of Vireet Investment P. Ltd. (2017) 165 ITD 27 (Del) wherein it was held that the addition under clause (f) of Explanation 1 to Section 115JB(2) relating to exempt income should be computed ....

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....ssessee also took us to the working made by it for ascertaining the expenses relating to exempt income for the purpose of computation of book profit under Section 115JB of the Act. We noticed that the assessee has allocated expenses in the ratio of taxable income and exempt income and the said method was determined by the Department in A.Y. 2000-01. It is stated that the same method is being follo....