2018 (1) TMI 1421 - HC - Income Tax

Disallowance u/s 14A - whether the explanation of the assessee and the amount offered to tax under Section 14A could not have been rejected by the AO in the manner that he did? - Held that - Besides the fact that the findings are concurrent, the Court is of the opinion that the facts of this case are such that no interference is called for. As against the exempt income of ₹ 48,447/-, the assessee had itself offered ₹ 2,58,620/- as disallowance. AO however, disallowed the astronomically high figure of ₹ 3,57,82,473/-. The concurrent view of the lower appellate authorities based upon the settled principle enunciated in previous authorities cannot be faulted. The appeal is accordingly dismissed.

Summary

The High Court upheld the decision of the ITAT and the CIT (A) regarding disallowance under Section 14A. The Assessing Officer's rejection of the assessee's explanation and offered amount was deemed inappropriate. The appeal was dismissed as the facts supported the lower authorities' decision based on settled principles.