9911796707
TMI Blog2019 (8) TMI 978X X X X Extracts X X X X X X X X Extracts X X X X ..... he impugned addition made by the assessing officer without giving reason for its justification, therefore, we are of the view that no interest expenditure should be disallowed u/s. 14A r.w. rule 8D in the case of the assessee. Regarding administrative expenditure, we are of the view that no exempt income can be earned without incurring any administrative expenditure, therefore, we restore this issue of computing administrative expenditure incurred for earning exempt income to the file of assessing officer and direct the assessing officer to compute administrative expenditure @ 0.5% of investment from which the assessee has earned the tax free income. Therefore, the appeal of the assessee is partly allowed. X X X X Extracts X X X X X X X X Extracts X X X X ..... employees, in relation to investment portfolio, stationary, computer etc. Therefore, the assessing officer has computed the disallowance as per provision of section 14A r.w.s. Rule 8D to the amount of s. 94,76,690/- and added to the total income of the assessee. 3. Aggrieved assessee has filed appeal before the ld. CIT(A). The ld. CIT(A) has confirmed the disallowance made by the assessing officer reiterating the same reason mentioned by the assessing officer. 4. During the course of appellate proceedings before us, the ld. counsel has submitted paper book containing information and submission made before the assessing officer and ld. CIT(A) during the course of assessment and appellate proceedings. He has also placed reliance on the fol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... free funds and investment made by the assessee are reproduced as under:- Particulars As at 31/03/2013 As at 30/11/2013 As at 31/03/2014 Capital + Reserves 23,16,75,312/- 23,16,75,312/- 44,01,43,494 Profit earned till date N.A. 25,53,06,095 N.A. Total Own Funds 23,16,75,312 48,69,81,407 44,01,43,494 Investments 1,74,62,596 6,73,93,632 42,30,86,522 We have also noticed from the balance sheet of the assessee company placed in the paper book at page no. 12 that assessee was having interest free fund to the amount of ₹ 44 crores and the investment made by the assessee company was to the amount of ₹ 42 crores as on 31st March, 2014. After considering the above material fact and material on record, w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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