Section 14A Disallowances cannot be applied to provision of Section 115JB

Gujarat Urja Vikas Nigam Board Vs DCIT (ITAT Ahmedabad) The AO during the assessment proceedings has made the disallowance of Rs.50.85 crores in determining the income under normal computation of income under the provisions of Section 14A read with Rule 8D of Income Tax Rule. The AO made the addition of the same disallowance while determining the income of the assessee under the provisions of Section 115JB of the Act. The Learned AR before us contended that disallowance made under the provisions of Section 14A read with Rule 8D under normal computation of income cannot be added to the income d...