2021 (10) TMI 419

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.... have erred in making the addition of Rs. 28,85,273/- u/s 14A read with Rule 8D without considering the various judgments and fact that the investments in mutual funds are managed through Portfolio manager Citi bank for which the bank has charged fees of Rs. 17,13,110/- for the year & the disallowance of Rs. 17,13,287/- has already been made by the assessee company in its return of income. No other expenditure has been incurred by the assessee company in this regard." 2. A perusal of the above ground of appeal reveals that the issue raised by the assessee in this appeal is relating to the confirmation of disallowance of Rs. 28,85,273/- made u/s 14A read with Rule 8D (2)(iii) of the Income Tax Rules, 1962 (hereinafter referred to 'the Rule....

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.... during the year, the assessee had made investment in mutual funds only, which were managed through Portfolio manager City bank, which has charged a fees of Rs. 17,13,110/- and in addition that STT amounting to Rs. 117/- was also paid . It was explained that no other expenditure was incurred by the assessee in respect of investment in mutual funds, therefore, the assessee company rightly disallowed of Rs. 17,13,110/- on account of expenditure relatable to earning tax exempt income. The Ld. Counsel for the assessee has also submitted that under similar circumstances, in the previous year, the Ld. CIT(A) has accepted the contention of the assessee and the disallowance was restricted to the fees paid to the Portfolio manager. However, this yea....