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TMI Blog2014 (1) TMI 1183X X X X Extracts X X X X X X X X Extracts X X X X ..... to be made which can be attributed to the income which is chargeable to tax particularly bank interest income as against dividend income – the expenditure as worked out by assessee, the details of which are mentioned by AO is reasonable to make disallowance u/s 14A with Rule 8D - the disallowance restricted to Rs.7,21,927 – Decided in favour of Assessee. - I.T.A. No.7598/Mum/2011 - - - Dated:- 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing heads : Dividend on units of mutual funds Rs.12,46,33,832 Dividend on shares Rs.16,143 Profit on sale of investments Rs.6,97,926 Interest income on inter-corporate deposits Rs.15,66,782 Bank interest income Rs.28,40,95,006 Other interest Rs.8,411 Other interest Rs.36 Provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .13,73,731/-, as against working made by assessee of Rs.7,21,927/-, the AO made total disallowance u/s 14A r.w.Rule 8D of the Rules of Rs.13,73,731/-. The assessee disputed the above action of the AO before the First Appellate Authority and submitted that reasonable allocation of expenditure has to be made in proportion to the income not forming part of total income under the Act. The ld. CIT(A) c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s.4,36,012/- besides other expenses like bank charges, profession tax, filing fees, etc. Considering the nature of expenses and the income shown by the assessee, we agree with ld. AR that entire expenditure debited by assessee in its profits and loss account could not be said to have been incurred only for earning exempt income under the Act. 5. We are of the considered view that a reasonable al ..... X X X X Extracts X X X X X X X X Extracts X X X X
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