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TMI Blog2018 (2) TMI 1215X X X X Extracts X X X X X X X X Extracts X X X X ..... hat:- We are fully in agreement with the view of the Tribunal. Under no circumstances, can the Assessing Officer attribute administrative expenses for earning tax free income in excess of the total administrative expenditure incurred by the assessee. If it is a case where Assessing Officer disputes, question and disallow the very declaration of the assessee regarding total administrative expenditu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 31st May 2017, raising the following questions for our consideration : [A] Whether the Appellate Tribunal has erred in law and on facts by deleting the addition of ₹ 88,231,450/= made under Section 14A of the Act on account of expenses incurred towards the exempted income as per Rule 8D of the Income Tax Rules ? [B] Whether the Appellate Tribunal has erred in law and on facts i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... flated the administrative expenditure shown by the assessee for earning such tax exempt income. The Tribunal found that the assessee had surplus tax free funds, and therefore, there was no question of disallowance of any interest income. We are however concerned with the latter portion of the disallowance, namely, that made by the Assessing Officer towards administrative expenditure. The Tribun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inistrative expenditure incurred by the assessee. If it is a case where Assessing Officer disputes, question and disallow the very declaration of the assessee regarding total administrative expenditure, the issue can be somewhat different. Nevertheless, when the Assessing Officer has in the present case did not disturb the assessee's declaration that total administrative expenses incurred by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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