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TMI Blog2014 (1) TMI 1884X X X X Extracts X X X X X X X X Extracts X X X X ..... e has to be made which can be attributed to the income which is chargeable to tax particularly bank interest income of ₹ 33.80 crores as against dividend income of ₹ 12.07 crores (approximately). Expenditure of ₹ 4,77,890/- as worked out by assessee, the details of which are mentioned by AO at page 2 of the assessment order, is reasonable to make disallowance u/s 14A with Rule ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s a company registered as a Non-Banking Finance Company with Reserve Bank of India with the main object to make investment in various classes of assets. The assessee filed its return of income declaring income on account of following heads : Dividend on units of mutual funds ₹ 12,06,75,902 Dividend on shares ₹ 17, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of expenses of ₹ 11,60,083/ debited by assessee in its profit and loss account. The AO applied Rule 8D of the Income Tax Rules, 1962 (the Rules) to make disallowance u/s 14A of the Act and worked out the disallowance at ₹ 1,35,12,590/-. There is no dispute that there is no interest expense debited by assessee in its profit and loss account for making aforesaid investments and earning ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther income of the assessee relates to merely bank interest, therefore entire expenditure could be said to have been incurred for earning dividend income only. 4. During the course of hearing before us, ld. AR referred the statement of facts which was filed before the ld. CIT(A) and copy placed along with Form No.35 giving details of the expenditure which includes auditor remuneration ₹ 6 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of ₹ 4,77,890/- as worked out by assessee, the details of which are mentioned by AO at page 2 of the assessment order, is reasonable to make disallowance u/s 14A with Rule 8D. Accordingly, we restrict the disallowance to ₹ 4,77,890/- by reversing the orders of authorities below and thus, allow the grounds of appeal taken by assessee. Hence, the grounds of appeal taken by assessee are ..... X X X X Extracts X X X X X X X X Extracts X X X X
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