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| The Tax Publishers2019 TaxPub(DT) 5250 (Kol-Trib) : (2019) 179 ITD 0022 : (2019) 202 TTJ 1127 INCOME TAX ACT, 1961
Section 14A
As disallowance of Rs. 1 lakh offered by assessee under section 14A was much more than the exempt income in the form of dividend of Rs. 1,850 earned by the assessee during the year under consideration, further disallowance made by AO under section 14A by applying rule 8D was not sustainable.
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Disallowance under section 14A - Expenditure against exempt income - Disallowance in excess of exempt income earned by assessee -
Assessee earned tax free dividend income of Rs. 1,800 and claimed suo moto disallowance under section 14A amounting to Rs. l lakh AO invoked rule 8D and worked out additional disallowance.Held: As disallowance of Rs. 1 lakh offered by assessee under section 14A was much more than the exempt income in the form of dividend of Rs. 1,850 earned by the assessee during the year under consideration, further disallowance made by AO under section 14A by applying rule 8D was not sustainable.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12 & 2010-11
INCOME TAX ACT, 1961
Section 36(1)(va) Section 43B, Proviso
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