9911796707
TMI Blog2014 (5) TMI 658X X X X Extracts X X X X X X X X Extracts X X X X ..... rom export turnover has to be reduced from total turnover as well – Following Income-Tax Officer. Versus Sak Soft Limited [2009 (3) TMI 243 - ITAT MADRAS-D] - there was no infirmity in the order of CIT(A) – Decided against Revenue. Disallowance u/s 14A r.w. Rule 8D of the Act – Dividend income – Held that:- The assessee has made investments of yielding tax free income for the AY – Following God ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st the order of Commissioner of Income Tax (Appeals)-II, Chennai, dated 25.10.2013 relevant to the assessment year 2006-2007. 2. The assessee is a private limited company engaged in the business of clearing forwarding, manufacturing, trading and ship management services. The assessee filed its return for the assessment year 2006-07 on 30.12.2006 declaring its income as B7,06,89,035/-. During ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... total turnover in accordance with the decision of the Special Bench of Tribunal in the case of ITO vs M/s. Sak Soft Ltd, reported as 313 ITR(AT) 353. As regards disallowance u/s.14A, the Commissioner of Income Tax (Appeals) held that the provisions of Rule 8D are not applicable in the assessment year under consideration and thus made disallowance of 5% of dividend income. Now the Revenue has come ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been consistently followed. Keeping in view the decision of Special Bench, we do not find any infirmity in the order of Commissioner of Income Tax (Appeals) on the issue. 5. In the second ground of appeal, the Revenue is aggrieved against restricting of disallowance u/s14A to 0.5% of dividend income. A perusal of the impugned order shows that the assessee has made investments of over B24 Crore ..... X X X X Extracts X X X X X X X X Extracts X X X X
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