Section 14A / Rule 8D(2) cannot be invoked for making disallowance u/s 115JB

 Sri Vishnu Shankar Mill Vs ITO (ITAT Chennai) Section 14A read with Rule 8D(2) of the 1962 Rules cannot be invoked for making disallowance u/s 115JB of the 1961 Act but disallowance of expenses incurred relatable to earning of an exempt income is to be computed in accordance with Explanation 1(f) to Section 115JB of the 1961 Act, in accordance with ratio of decision of Special Bench in the case of Vireet Investment(supra). We also remit this matter back to the file of the AO for making additions to the Book Profit u/s.115JB in accordance with decision of the Hon’ble Special Bench of the tr...