Section 14A disallowance cannot exceed Actual Expense incurred for earning exempt income

India Infoline Finance Limited Vs ACIT (ITAT Mumbai)

The issue under consideration is whether the disallowance under 14A can be exceed the actual expenditure incurred in this regard?

ITAT states that, the assessing officer has duly rejected the assessee’s contentions and applied Rule 8D(3) and made the disallowance which has been sustained by learned CIT(appeals). However we are of the considered opinion that the issue may be considered by the assessing officer once more

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