Section 14A Onus Is On AO To Show Nexus Between Tax-Free Income & Exp: ITAT Delhi

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From: editor@itatonline.org <itatonline.org@gmail.com>
Date: Fri, May 18, 2012 at 10:04 AM
Subject: Message from EGroup of SolapurCAs S. 14A Onus Is On AO To Show Nexus Between Tax-Free Income & Exp: ITAT Delhi
To: editor@itatonline.org

 

Dear Subscriber,

 

The following important judgement is available for download at itatonline.org.

ACIT vs. SIL Investment Ltd (ITAT Delhi)

S. 14A: Onus is on AO to show expenditure is incurred to earn tax-free income

 

For AY 2006-07, the assessee earned dividend of Rs. 17 lakhs and LTCG of Rs. 12 crores. The assessee claimed that it had incurred no expense to earn the tax-free income and so no s. 14A disallowance was permissible. However, the AO disallowed Rs. 2 crores under Rule 8D towards interest and admin expenditure. The CIT (A) accepted that no interest was incurred and deleted that disallowance. He also reduced the admin expenditure disallowance. On appeal to the Tribunal, HELD:

(Click Here To Read More)

Regards,

Editor,

itatonline.org

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