: the “assessee has incurred various kinds of expenses in its Profit and loss account. The investments have been made in various schemes of mutual funds. It is not possible that the assessee has not incurred any expenditure in connection with such investments and earnings of such dividend income. As this investment is substantial assessee has used its resources to monitor and oversee the progress of such schemes of mutual funds. Therefore it cannot be said that no expenditure is attributable to such activities”. In view of the above extracted portion of the assessment order, it is clearly discernible that the AO recorded proper satisfaction before making disallowance u/s.14A.
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Computing of disallowance - whether investments which did not yield any tax free income during the year should have been excluded while computing the disallowance? - HELD THAT:- The Hon'ble Delhi High Court in ACB India Ltd. vs. CIT (2015 (4) TMI 224 - DELHI HIGH COURT] has held that the average value of in

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