KASHINATH REVAPPA DHOLE,SOLAPUR vs. ADDL. COMMISSIONER OF INCOME TAX, RANGE -1, SOLAPUR

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ITA 1278/PUN/2018Status: DisposedITAT Pune05 January 2022AY 2007-083 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that a disallowance of 2% of the exempt income is reasonable for earning such income, especially prior to the insertion of Rule 8D. Therefore, the Assessing Officer was directed to re-calculate the disallowance at 2%.

What were the facts?

The assessee earned exempt income from PPF and RBI bonds. The Assessing Officer disallowed Rs. 3,75,865/- under Section 14A, applying a 7.5% rate on exempt income. This was confirmed by the CIT(A).

What were the issues?

The primary issue was the disallowance of expenditure incurred for earning exempt income under Section 14A of the Income Tax Act, prior to the introduction of Rule 8D.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “B”, PUNE – VIRTUAL COURT

Before: SHRI INTURI RAMA RAO & SHRI RAVISH SOOD

For Respondent: Shri M. G. Jasnani
Hearing: 05.01.2022Pronounced: 05.01.2022

ORDER

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