2015 (2) TMI 1340

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.... the assessee relates to disallowance of Rs. 81,08,683/- u/s 14A of the Income Tax Act, 1961. 3. It was submitted by the ld. D.R. that the issue is covered against the assessee by the order of the Tribunal for the immediately preceding year. 4. On the other hand the ld. A.R. brought to our notice distinguishing feature to the effect that strategic investment was made by the assessee during the year which should not be taken into account while computing disallowance under Rule 8D(2)(iii). It was submitted by the ld. A.R. that all the investments, income from which is exempt, made by the assessee company are in the schemes of HDFC Mutual Fund. These investments made in the various schemes of HDFC Mutual Fund are usually made out of busi....

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.... disallowance upfront brokerage fees. 9. From the record we found that the A.O. has disallowed the said expenses on the ground that assessee has changed its accounting policy with regard to expense on upfront brokerage fees. We found that looking into the nature of expenses, the same were incurred in the revenue field and the same has been incurred wholly and exclusively for the purpose of business. The change in the accounting system is not violative of any regulations issued by regulatory authorities in this regard. Furthermore change in accounting policy is bonafide and in line with the industry practice. In earlier years the assessee witnessed many times either the clients exited from the scheme or they switched to the other scheme. ....