No Addition u/s 14A for Non Consideration of  Share Application Money as Investment Yielding Exempt Income

Kumar Urban Development Ltd Vs ITO (ITAT Pune) The issue under consideration is whether the addition made by AO u/s 14A read with rule 8D is justified in law? In the present case, the assessee made suo moto disallowance u/s.14A in terms of Rule 8D. The Assessing Officer (AO) observed that the assessee did not offer proper disallowance. He made his own calculation of assessment the order and worked out the amount disallowable. The differential amount was disallowed. The assessee submitted before the ld. CIT(A) that the difference in assessee’s calculation and that of AO arose primarily becaus...