2018 (3) TMI 1448 - SCH - Income Tax

Disallowance of expenditure in respect of interest and administrative expenses under Section 14A - Disallowance of expenditure incurred towards foreign exchange gain - Held that - SLP dismissed. HC order confirmed 2017 (5) TMI 1160 - GUJARAT HIGH COURT HC has correctly held that the assessee was already having its own surplus fund and that too to the extent of ₹ 2319.17 Crores against which investment was made of ₹ 111.09 Crores, there was no question of making any disallowance of expenditure in respect of interest and administrative expenses under Section 14A of the Act, therefore, there was no question of any estimation of expenditure in respect of interest and administrative expenses of ₹ 54,39,916/ under rule 8D. For expenditure incurred towards foreign exchange gain the assessee had incurred loss in the same account in the earlier assessment years as well as subsequent assessment year and the treatment given by the assessee has been accepted. Therefore, the learned CIT A as well as the Tribunal has rightly deleted the disallowance made on account of foreign gain. - Decided against revenue.