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TMI Blog2019 (12) TMI 1651X X X X Extracts X X X X X X X X Extracts X X X X ..... he decision making process was very complicated which required careful analysis from the top management - CIT(A) has dismissed the appeal of the assessee after considering the size of the investment stating that one employee cannot make investment decision - HELD THAT:- We observe that disallowance of only 10% of one employee as a cost of administrative expenditure to the amount is not sufficient ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... UNTANT MEMBER:- This assessee s appeal for A.Y. 2013-14, arises from order of the CIT(A)-8, Ahmedabad dated 14-03-2018, in proceedings under section 143(3) of the Income Tax Act, 1961; in short the Act . 2. The solitary ground of appeal of the assessee is against the decision of ld. CIT(A) in confirming the addition of other expenses of Rs. 6,31,171/- u/s. 14A r.w.r. 8D as against the dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g officer has not agreed with the explanation of the assessee and stated at para 7.3.5 of the assessment order that to retain the investment or to liquidate the investment the management has to make very strategic decision. The assessing officer has further stated that top management was involved in taking decision and the decision making process was very complicated which required careful analysi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estment stating that one employee cannot make investment decision. 5. We have hard rival contention and perused the material on record. The assessee has earned exempt income to the amount of Rs. 1,01,44,039/-. The assessee itself has disallowed an amount of Rs. 45,000/- incurred towards cost of employee handled the work relating to investment activities of M.F. The assessing officer has conside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 45,000/- is not sufficient and appropriate looking to the size of the investment and the quantum of exempt income earned from the investment which was claimed as exempt. We are of the view that involvement of top executives and use of other business office equipment like computer etc. and office premises in respect of investment activities cannot be ruled out, therefore, we are of the view tha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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