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TMI Blog2013 (5) TMI 117X X X X Extracts X X X X X X X X Extracts X X X X ..... 2009 (5) TMI 615 - ITAT DELHI] the amount disallowed u/s 14A cannot be added to the amount of book profit u/s 115JB. Unless a particular expenditure is debited to the profit and loss account relating to the earning of exempt income, the same cannot be imported into the computation of book profit as clause (f) of Explanation 1 to section 115JB which only refers to the amount debited to the profit a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Revenue arise out of the order passed by the Commissioner of Income-tax (Appeals) on 14.05.2010 in relation to the assessment year 2007-2008. 2. The only issue raised by the assessee in its appeal is computation of disallowance u/s 14A read with Rule 8D. 3. We have heard the rival submissions and perused the relevant material on record. It is noted that the question of making disallowance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eriod expenses while computing profits u/s 115JB of the Act. 5. We have heard the rival submissions and perused the relevant material on record. It is observed that the Assessing Officer added the amount disallowed by him u/s 14A to the tune of Rs.78.84 lakh to the book profit computed u/s 115JB. The learned CIT(A) ordered for the deletion of this amount. The learned AR has placed on record a co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... so placed on record one more order passed by the Delhi Bench in the case of Quippo Telecom Infrastructure Ltd. v. ACIT in ITA No.4931/Del/2010 in which it has been reiterated that the amount disallowed u/s 14A cannot be considered while computing book profit u/s 115JB of the Act. No contrary decision has been brought on record by the learned Departmental Representative. In view of these facts, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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