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TMI Blog2013 (6) TMI 248X X X X Extracts X X X X X X X X Extracts X X X X ..... ed in deleting the addition of Rs.15,48,740/- made u/s 14A of the IT Act, read with Rule 8Dof the Income Tax Rule, 1962. 2. In support of the ground the ld. DR has basically placed reliance on the assessment order. 3. Having gone through the orders of the authorities below, we find that the AO had made disallowance of Rs.22,17,677/- u/s 14A of the Income Tax Act 1961, read with Rule 8D of the IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... details filed. Thus the assessee tried to justify the Suo- moto disallowance made by it u/s 14A of the Act at Rs.1,00,000/- in its return of income filed for the assessment year under consideration. In the said computation the assessee has considered the explained interest expenditure of Rs.13,938/- besides 10% salary paid to the concerned persons of the treasury team for the financial year 2006- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of making investments in shares and mutual funds and the earning of the dividend income. He accordingly has estimated the administrative expenses at the rate of 0.1% of the total value of purchases and sales of the shares of group companies of Rs.65,49,99,000/- resulting in Rs.6,54,999/-. The ld. CIT (A) has accordingly made disallowance of Rs.6,68,937/- giving relief of Rs.15,48,740/-. This acti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d if he is satisfied on an objective analysis and for cogent reasons that amount of such expenditure as claimed by assessee is not correct, he is required to determine amount of such expenditure on the basis of reasonable and acceptable method of apportionment, the Hon'ble High Court has answered it in affirmative. 6. We find that in the present case the ld. CIT (A) has not given plausible basis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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