Section 14A disallowance when Expenditure incurred against earning of exempted income disallowed voluntarily by Assessee

Pr. CIT Vs M/s. Lee & Murihead Pvt Ltd (Bombay High Court)

Sub-section (2) of section 14A of Income Tax Act, 1961  provides that Assessing Officer would determine the amount of expenditure incurred in relation to income which not forms part of total income if he is not satisfied with the correctness of claim of assessee in respect of such expenditure. If expenditure already voluntarily disallowed by assessee was found to be reasonable, Assessing Officer in any case could not have resorted to rule 8D of Income Tax Rules.

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