AO
made huge disallowance u/s 14A on the basis of Rule 8D of the Income-tax Rules,
1962. Hon’ble ITAT observed that apart from purchase and depreciation, only
three expenses were debited to the P&L account viz. Administrative
expenses, interest expenses and other expenses. Out of the same, assessee had
disallowed entire interest expenses while computing her income. CIT(A) had
confirmed the addition made by AO to the extent of aggregate of administrative
and other expenses and deleted the balance amount of addition. It was held that
no addition can be made u/s 14A in respect purchases and depreciation. Since rest
of the three expenses were either disallowed by assessee or confirmed by
CIT(A), no further addition can be sustained u/s 14A in excess of the amount
debited to P&L account.
[ACIT
vs. Smt. Neeta M. Patel – ITA No.1964/Ahd/2012]
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