2010 (10) TMI 654

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..... s a reasonable allocation expenses to earn the interest free income, the CIT(A) has restricted also a reasonable disallowance of Rs.25,000/- as against Rs.6,74,003 - The disallowance of expenses on the basis of proportionate basis on income parameter certainly cannot be said to be reasonable on the facts of this case - Decided against the revenue
N.V. Vasudevan, Pramod Kumar, JJ. Keshava Saxen .....

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..... /s 14A. The Assessing Officer was of the opinion that the expenditure of Rs.6,96,002/- claimed by the assessee, as net expenses, are related to earning of tax free dividend and computed the proportionate amount disallowable at Rs.6,74,003/- u/s 14A. 3. In appeal, the CIT (A) accepted the contention of the assessee that 97% of the dividend amount is received from a single company and, there canno .....

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..... ate disallowance of Rs.6,74,003/- as a reasonable allocation expenses to earn the interest free income, the CIT(A) has restricted also a reasonable disallowance of Rs.25,000/- as against Rs.6,74,003/- disallowed by the AO after taking into consideration the facts of this case. The disallowance of expenses on the basis of proportionate basis on income parameter certainly cannot be said to be reason .....

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