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TMI Blog2016 (3) TMI 1351X X X X Extracts X X X X X X X X Extracts X X X X ..... he income which is chargeable to tax particularly bank interest income as against dividend income. Thus expenditure as worked out by assessee is reasonable to make disallowance u/s 14A read with Rule 8D. Thus remand the matter to the file of AO and direct the AO to apply the said ratio to the facts of the present case and other decisions, if any, in force and decided the issue in accordance wit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... following paragraphs of this order. 2. The only issue raised in these two appeals relates to the disallowance u/s 14A read with Rule 8D of the Act. In connection with this issue, Ld Counsel for the assessee submitted that the disallowance made by the AO has far exceeded the total claim of expenditure in the P L Account. Bringing our attention to the order of the Tribunal in assessee s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is relevant in this regard. Considering the significance of the said para 5 of the Tribunal s order (supra), the same is extracted as under:- 5. We are of the considered view that a reasonable allocation of expenditure has to be made which can be attributed to the income which is chargeable to tax particularly bank interest income of ₹ 28.50 Crs as against dividend income of S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and decided the issue in accordance with law. AO shall grant a reasonable opportunity of being heard to the assessee as per the set principles of natural justice. Accordingly, all the grounds raised in both the cross appeals are allowed for statistical purposes. 5. In the result, both the cross appeals are allowed for statistical purposes. Order pronounced in the open court on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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