Depreciation cannot be considered for computing section 14A disallowance

Sudha Apparels Ltd. Vs DCIT (ITAT Kolkata) Section 14A deals only with the expenditure and not any statutory allowance admissible to the assessee.  Section 14A uses the words expenditure incurred by the assessee in relation to income. A statutory allowance under section 32 is not an expenditure.  So Depreciation claimed by assessee under section 32 cannot be considered for the purpose of computing disallowance under section 14A As section 14A deals only with the expenditure and not any statutory allowance, such as depreciation under section 32 of Income Tax Act, 1961. FULL TEXT OF THE ITAT J...