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TMI Blog2023 (7) TMI 376X X X X Extracts X X X X X X X X Extracts X X X X ..... tment activities cannot be ruled out. Therefore, the Tribunal in A.Y. 2013-14 restricted the disallowance under administrative expenditure to the amount of Rs. 4,00,000/-. At the time of hearing it appears that the assessee has made investment of Rs. 102.72 crore and profit for the year was Rs. 28.38 crore. The interest expenditure was Rs. 44.38 lakhs and therefore, in the present case also the calculation of Rs. 4,37,612/- is justifiable under administrative expenditure. Therefore, the appeal of the assessee is partly allowed. - I.T.A. No. 221/Ahd/2023 - - - Dated:- 5-7-2023 - Ms. Suchitra Kamble, Judicial Member For the Appellant : Shri Dhinal Shah, A.R. For the Respondent : Shri Urjit Shah, Sr. D.R. ORDER The appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dend income and the same was claimed as exempt under Section 10(34) and Section 10(35) of the Act. The Assessing Officer after taking consideration of the reply of the assessee disallowed / made addition of Rs. 30,63,680/- in respect of disallowance under Section 14A r.w.s. 8D. The Assessing Officer further made addition of Rs. 16,252/- in respect of Section 2(24)(x) r.w.s. 36(1)(va) of the Act. 4. Being aggrieved by the assessment order the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. The Ld. A.R. submitted that the CIT(A) was not right in confirming the disallowance of other expenses of Rs. 4,82,612/- under Section 14A r.w.r. 8D in as much as the assessee has not incurred any expe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee has earned exempt income to the extent of Rs. 88,58,283/-. Though the assessee has not made any corresponding disallowance under Section 14A the contention of the assessee that the assessee invested substantial amount in Mutual Fund after the date of which the assessee has received the amount of share capital, including securities premium of Rs. 74.54 crore and the assessee has securities premium of Rs. 28.17 crore at the beginning of the year. So the total amount of securities premium amounts to Rs. 102.72 crore and profit for the year was Rs. 28.38 crore. The assessee invested in Mutual Fund only out of the interest free capital as per the record stand before the Assessing Officer by the assessee. The contention of the assessee th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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