2013 (10) TMI 224

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..... e should not be seen to have confirmed the Tribunal's view on the aspect that in absence of Rule 8D, no disallowances can be made under Section 14A of the Act, by proportionate bifurcation of the expenditure - Decided against Revenue. - TAX APPEAL NO. 526 of 2012 - - - Dated:- 19-2-2013 - AKIL KURESHI AND SONIA GOKANI , JJ. For the Appellant : Ms. Paurami B. Sheth. ORDER:- PER : Aki .....

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..... tion 14A of the Act. Since no bifurcation was made by the assessee, the Assessing Officer disallowed the total expenditure under this head. In the result, he added back a sum of Rs.3,25,868/-being the amount of salary. 3. Commissioner(Appeals) and Tribunal did not approve such decision of the Assessing Officer. The Tribunal, in particular, relied on its earlier decision on the issue. In such dec .....

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..... t, however, does not mean in our prima-facie opinion that no disallowances can be made under Section 14A of the Act by bifurcating the expenditure in a reasonable manner towards earning of the taxable income and tax exempt income. 5. In the present case, since the amount involved is not very large, we reserve our final conclusion on such an issue in appropriate case. Therefore, we are not inclin .....

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