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TMI Blog2013 (2) TMI 664X X X X Extracts X X X X X X X X Extracts X X X X ..... id to be a reasonable basis on the facts fo the case. Therefore, we do not find any reason to deviate from such a finding given by the learned Commissioner (Appeals). There is no merit in the ground raised by the Revenue which is mainly on the ground that the judgment of the Hon'ble Jurisdictional High Court in Godrej & Boyce Mfg. Co. Ltd. (supra) has not been accepted by the Department and Sp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned CIT(A) erred in directing the Assessing Officer to recompute the disallowance u/s 14A on a reasonable basis relying on the judgment of Hon'ble Jurisdictional High Court in Godrej Boyce Mfg. Ltd. without appreciating the fact that the judgment of Bombay High Court has not been accepted by the Revenue and SLP has been proposed. 2. The Assessing Officer, in the present case, noted th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... easonable amount of deduction should be made for making the disallowance. He noted that the assessee has itself offered ₹ 10,000, as a reasonable amount to be disallowed u/a 14A, therefore, the disallowance should be restricted to 10% of the dividend income earned so as to be treated as reasonable expenditure attributable to earning of the said income. 3. After hearing the rival contentio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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