ection 115JB MAT computation is no more res integra. Hon’ble Bombay high court’s judgment in CIT vs. Bengal Finance & Investment P Ltd. [2015 (2) TMI 1263 - BOMBAY HIGH COURT] and this Tribunal’s Special Bench decision in ACIT vs. Vireet Investments (P) Ltd. [2017 (6) TMI 1124 - ITAT DELHI] settle this issue in assessee’s favour that such a disallowance is not to be subjected to MAT adjustment.
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Disallowance u/s 14A - AO invoked section 14A r.w.r. 8D(i) on direct expenses disallowance on brokerage, security transaction tax and other similar charges - HELD THAT:- Suffice to say, it fails to dispute the crucial fact recorded in the CIT(A)’s findings that the assessee had capitalized the above direct expenditure than claiming it as revenue expenditure by debiting the same through Profit & Loss account. We further find that the Revenue’s instant argument carries no substances since direct expenses sought to be disallowed have nowhere been claimed at assessee’s behest.The Revenue’s fir

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