9911796707
Advanced Search 
TMI Blog2016 (4) TMI 309X X X X Extracts X X X X X X X X Extracts X X X X ..... 2012, determining the income of the assessee at Rs. 17. 24 lakhs. 2. First ground of appeal is about disallowance made under section 14 A of the Act. During the assessment proceedings, the AO found that the assessee had claimed exempt income, that it had not made any disallowance under section 14 A of the Act. He called for relevant details from the assessee in that regard. He asked the assessee to show cause as to why the disallow - ance u/s. 14 A should not be made. It was submitted by the assessee that no disallowance could be made under rule 8D of the income tax rules, 1962 (Rules), that no interest-bearing funds were incurred by the assessee for making investments, that no other administrative expenses could be attributable to the ear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... self had made a disallowance of Rs. 17, 503/-pertaining to the demat charges, that no other expense was incurred by the assessee for earning the exempt income, that the AO had applied the A read with rule 8D without applying his mind and had made the disallowance mechanically. Departmental Representative (DR) supported the order of the FAA. 5. We have heard the rival submissions and perused the material on record. We find that the assessee had earned dividend income of Rs. 1. 08 lacs, that it had made a disallowance of Rs. 17, 503/- on its own as per the provisions of Sec. 14A of the Act, that the AO had made a dsisallowance of Rs. 2. 02 lakhs, that the AO had not mentioned as to how much expenditure was incurred by the assessee for earnin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t time interest rate was hovering to an average of 6-7% approximately. Loan advanced to its broker was received back by the assessee in the year under consideration, that it had advanced loan to other parties after taking into consideration availability of funds, that the different lending rates at different times were just and rational to carry out the business. However, the AO was not satisfied with the reply of the assessee and added Rs. 34, 038/- (difference between the lending rates) to the total income of the assessee. 7. During the appellate proceeding before the FAA, the assessee contended that there was no provision in the Act to add notional interest by an AO by comparing other internal/external rates of interest, that the AO cou ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
