Indiabulls Financial Services Ltd. v. DCIT

395 ITR 242High Court2017#6291 most cited
19

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2025.

Sections most often in play

Section 115JBSection 14ASection 10(34)Section 10(38)Section 142(1)Section 143(3)Section 14A(2)Section 14A(3)

Issues it is cited on

trade creditorssection 14a(2)income tax settlement commissioninterest free advancessection 142(2a)business connectionsection 41(1)section 41rejection of books of accountblock periodsection 40a(3)commercial expediency

Judgments citing Indiabulls Financial Services Ltd. v. DCIT

J.M FINANCIAL AND INVESTMENT CONSULTANCY SERVICE PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(1), MUMBAI

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 5768/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Nov 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16

For Appellant: Mr. K Shivram a/wFor Respondent: 11/11/2025
Section 14A

…w has in fact been recorded, and recorded with reasons. Moreover, as ith reasons. Moreover, as clarified by the Hon’ble Delhi High Court in Indiabulls Investment Indiabulls Investment clarified by the Hon’ble Delhi High Court in Pvt. Ltd. v. Dy. CIT T [2017] 395 ITR 242, where the Assessing where the Assessing Officer undertakes a detailed analysis and follows the statutory Officer undertakes a detailed analysis and follows the statutory Officer undertakes a detailed analysis and follows the statutory procedure in computing the disallowan procedure in computing the disallowance, the mere absence of an ce, the me…

DCIT-1(2)(1), MUMBAI., MUMBAI vs. INDIAN CLEARING CORP ORATION LIMITED, MUMBAI

In the result, appeal of the revenue is dismissed

ITA 873/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Aug 2025AY 2014-15
For Appellant: Shri Niraj D. Sheth, A/RFor Respondent: Mr. Virabhadra S. Mahajan, Sr. D/R
Section 14ASection 14A(1)

…l for the assessee reiterated what has been stated\nbefore the lower authorities. The ld. D/R supported his submissions by\ndrawing support from the decisions of the Hon'ble High Court of Delhi\nin the case of Indiabulls Financial Services Ltd. Vs DCIT [2017] 395 ITR 242\n(Delhi).\n6. We have carefully considered the orders of the authorities below.\nIt is true that the assessee has suo moto disallowed Rs.19.49 Lakhs and\nhas computed the disallowance as under:-\n| Sr.\nNo. |\nParticulars\nAmount\n| |\n1 |\nInfrastructure Expenses\n(Rent)\n38\n2 |\nAuditors Remuneration\n8\n3 |\nMiscellaneous Expenses\n37\n4 |\nE…

INDIABULLS REAL ESTATE LIMITED,NEW DELHI vs. DCIT CENTRAL CIRCLE 12(1), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5954/DEL/2019[2013-14]Status: DisposedITAT Delhi17 May 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumarm/S. Indiabulls Real Estate Ltd, Vs. Dcit, M-62 & 63, First Floor, Central Circle-12(1), Connaught Place, New Delhi New Delhi (Appellant) (Respondent) Pan:Aabci5194F

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Sandip Kumar Mishra, Sr. DR
Section 143(3)Section 14ASection 14A(2)

…e rejecting the same. (2) Section 14A would be applicable only to income arising from the investment portfolio and not from stock-in-trade. M/s. Indiabulls Real Estate Ltd 2. Indiabulls Financial Services Ltd. Vs DCIT [2016] 76 taxmann.com 268 (Delhi)/[2017] 395 ITR 242 (Delhi) where Hon'ble Delhi High Court held that where Assessing Officer after carrying out elaborate analysis and following steps enacted in statute, had determined amount of expenditure incurred for earning tax exempt income, merely because he did not expressly record his dissatisfaction about assessee's calculation, his conclusion could not be…

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

ITA 323/PUN/2021[2013-14]Status: DisposedITAT Pune15 Sept 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri J. P. Chadraker
Section 10ASection 14ASection 35Section 35(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “C”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI S. S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं. / ITA No.323/PUN/2021 िनधा"रण वष" / Assessment Year: 2013-14 DCIT, Circle-5, Pune. Vs. Serum Institute of India Ltd., 212/2, Off Soli Poonawalla Road, Hadapsar, Pune- 411028. PAN : AABCS4225M Appellant Respondent Revenue by : Shri J. P. Chadraker Assessee by : Shri Percy Pardiwalla Shri Sukh Sagar Syal Date of hearing : 11.08.2022 Date of pronouncement : 15.09.2022 आदेश / ORDER PER INTURI RAMA RAO, AM: This is an appeal filed by the Revenue direct…

NATH BROS. EXIM INTERNATIONAL LTD.,NEW DELHI vs. ACIT, CIRCLE- 17(2), NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 157/DEL/2018[2014-15]Status: DisposedITAT Delhi12 Mar 2021AY 2014-15

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 14A

…e u/s 14A and Rule 8D at Rs. 70,643/-. The objection raised by appellant that AO has not recorded any objective satisfaction in regard to the correctness of claim of the assessee has no force as recently in the case IndiaBulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that if the AO has carried elaborate analysis out of facts and the issue but did not expressly record his dissatisfaction, would not per say justify that he was not satisfied or did not record cogent reasons for his dissatisfaction. It has been further held by Hon'ble Court to insist that the AO should pay s…

MINDA PROJECTS LTD,NEW DELHI vs. DCIT, CIRCLE-16(2), NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 6503/DEL/2017[2014-15]Status: DisposedITAT Delhi11 Mar 2021AY 2014-15

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)Section 14A

…s 14A and Rule 8D at Rs, 21,05,899/-. The objection raised by appellant that AO has not recorded any objective satisfaction in regard to the correctness of claim of the assessee has no force as recently in the case India Bulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that if the AO has carried elaborate analysis out of facts and the issue but did not expressly record his dissatisfaction, would not per say justify that he was not satisfied or did not record cogent reasons for his dissatisfaction. It has been further held by Hon'ble Court to insist that the AO should pay s…

ACIT, CENTRAL CIRCLE- 19, NEW DELHI vs. AMQ AGRO INDIA PVT. LTD., NEW DELHI

In the result, both the appeals of the assessee are partly allowed and both the appeals of the revenue are dismissed

ITA 4409/DEL/2018[2014-15]Status: DisposedITAT Delhi22 Jan 2021AY 2014-15

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 2805/Del/2018 : Asstt. Year : 2013-14 Ita No. 2806/Del/2018 : Asstt. Year : 2014-15 M/S Amq Agro India Pvt. Ltd. Vs Asstt. Commissioner Of Income C-134, Ground Floor, Defence Tax, Central Circle-19, Colony, New Delhi-110024 New Delhi (Appellant) (Respondent) Pan No. Aaeca0929M

For Appellant: Sh. Sh. Hiren Mehta, CA &For Respondent: Ms. Pramita M. Biswas, CIT DR
Section 153A

…to the tune of Rs.7.8 Cr. and at the end of the year were of Rs.8.6 Cr. The average investments being Rs.8.2 Cr. on which Rs.4.1 lacs has been disallowed by the AO being 0.5% of the average investments. In the case Indiabulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that undoubtedly, the language of Section 14A presupposes that the AO has to adduce some ITA Nos. 2805, 2806, 4408 & 4409/Del/2018 54 AMQ Agro India Pvt. Ltd. reasons if he is not satisfied with the amount offered by way of disallowance by the assessee. In the instant case, the AO have issued notice on 23.…

DCIT, CENTRAL CIRCLE- 19, NEW DELHI vs. AMQ AGRO INDIA PVT. LTD., NEW DELHI

In the result, both the appeals of the assessee are partly allowed and both the appeals of the revenue are dismissed

ITA 4408/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Jan 2021AY 2013-14

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 2805/Del/2018 : Asstt. Year : 2013-14 Ita No. 2806/Del/2018 : Asstt. Year : 2014-15 M/S Amq Agro India Pvt. Ltd. Vs Asstt. Commissioner Of Income C-134, Ground Floor, Defence Tax, Central Circle-19, Colony, New Delhi-110024 New Delhi (Appellant) (Respondent) Pan No. Aaeca0929M

For Appellant: Sh. Sh. Hiren Mehta, CA &For Respondent: Ms. Pramita M. Biswas, CIT DR
Section 153A

…to the tune of Rs.7.8 Cr. and at the end of the year were of Rs.8.6 Cr. The average investments being Rs.8.2 Cr. on which Rs.4.1 lacs has been disallowed by the AO being 0.5% of the average investments. In the case Indiabulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that undoubtedly, the language of Section 14A presupposes that the AO has to adduce some ITA Nos. 2805, 2806, 4408 & 4409/Del/2018 54 AMQ Agro India Pvt. Ltd. reasons if he is not satisfied with the amount offered by way of disallowance by the assessee. In the instant case, the AO have issued notice on 23.…

AMQ AGRO INDIA PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 19, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and both the appeals of the revenue are dismissed

ITA 2806/DEL/2018[2014-15]Status: DisposedITAT Delhi22 Jan 2021AY 2014-15

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 2805/Del/2018 : Asstt. Year : 2013-14 Ita No. 2806/Del/2018 : Asstt. Year : 2014-15 M/S Amq Agro India Pvt. Ltd. Vs Asstt. Commissioner Of Income C-134, Ground Floor, Defence Tax, Central Circle-19, Colony, New Delhi-110024 New Delhi (Appellant) (Respondent) Pan No. Aaeca0929M

For Appellant: Sh. Sh. Hiren Mehta, CA &For Respondent: Ms. Pramita M. Biswas, CIT DR
Section 153A

…to the tune of Rs.7.8 Cr. and at the end of the year were of Rs.8.6 Cr. The average investments being Rs.8.2 Cr. on which Rs.4.1 lacs has been disallowed by the AO being 0.5% of the average investments. In the case Indiabulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that undoubtedly, the language of Section 14A presupposes that the AO has to adduce some ITA Nos. 2805, 2806, 4408 & 4409/Del/2018 54 AMQ Agro India Pvt. Ltd. reasons if he is not satisfied with the amount offered by way of disallowance by the assessee. In the instant case, the AO have issued notice on 23.…

AMQ AGRO INDIA PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 19, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and both the appeals of the revenue are dismissed

ITA 2805/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Jan 2021AY 2013-14

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 2805/Del/2018 : Asstt. Year : 2013-14 Ita No. 2806/Del/2018 : Asstt. Year : 2014-15 M/S Amq Agro India Pvt. Ltd. Vs Asstt. Commissioner Of Income C-134, Ground Floor, Defence Tax, Central Circle-19, Colony, New Delhi-110024 New Delhi (Appellant) (Respondent) Pan No. Aaeca0929M

For Appellant: Sh. Sh. Hiren Mehta, CA &For Respondent: Ms. Pramita M. Biswas, CIT DR
Section 153A

…to the tune of Rs.7.8 Cr. and at the end of the year were of Rs.8.6 Cr. The average investments being Rs.8.2 Cr. on which Rs.4.1 lacs has been disallowed by the AO being 0.5% of the average investments. In the case Indiabulls Financial Services Ltd. Vs. DCIT 395 ITR 242, Hon'ble Jurisdictional Court has held that undoubtedly, the language of Section 14A presupposes that the AO has to adduce some ITA Nos. 2805, 2806, 4408 & 4409/Del/2018 54 AMQ Agro India Pvt. Ltd. reasons if he is not satisfied with the amount offered by way of disallowance by the assessee. In the instant case, the AO have issued notice on 23.…

ACIT, NEW DELHI vs. M/S. INDIABULLS FINANCIAL SERVICES LTD., NEW DELHI

In the result, both the appeals of the revenue are dismissed

ITA 6603/DEL/2016[2012-13]Status: DisposedITAT Delhi11 Mar 2020AY 2012-13

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 6602/Del/2016 : Asstt. Year : 2012-13 Asstt. Commissioner Of Vs M/S Indiabulls Real Estate Ltd., Income Tax, Circle-12(1), M-62 & 63, First Floor, Connaught New Delhi Place, New Delhi-110001 (Appellant) (Respondent) Pan No. Aabci5194F

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Sh. Rajesh Kumar Kedia, CIT DR
Section 14A

…ncome arising from the investment portfolio and not from stock-in-trade. ITA Nos. 6602 & 6603/Del/2016 6 Indiabulls Real Estate Ltd. & Indiabulls Financial Services Ltd. 2. Indiabulls Financial Services Ltd. Vs DCIT [2016] 76 taxmann.com 268 (Delhi)/[2017] 395 ITR 242 (Delhi) where Hon’ble Delhi High Court held that where Assessing Officer after carrying out elaborate analysis and following steps enacted in statute, had determined amount of expenditure incurred for earning tax exempt income, merely because he did not expressly record his dissatisfaction about assessee's calculation, his conclusion could not be…

ACIT, NEW DELHI vs. M/S. INDIABULLS REAL ESTATE LTD., NEW DELHI

In the result, both the appeals of the revenue are dismissed

ITA 6602/DEL/2016[2012-13]Status: DisposedITAT Delhi11 Mar 2020AY 2012-13

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 6602/Del/2016 : Asstt. Year : 2012-13 Asstt. Commissioner Of Vs M/S Indiabulls Real Estate Ltd., Income Tax, Circle-12(1), M-62 & 63, First Floor, Connaught New Delhi Place, New Delhi-110001 (Appellant) (Respondent) Pan No. Aabci5194F

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Sh. Rajesh Kumar Kedia, CIT DR
Section 14A

…ncome arising from the investment portfolio and not from stock-in-trade. ITA Nos. 6602 & 6603/Del/2016 6 Indiabulls Real Estate Ltd. & Indiabulls Financial Services Ltd. 2. Indiabulls Financial Services Ltd. Vs DCIT [2016] 76 taxmann.com 268 (Delhi)/[2017] 395 ITR 242 (Delhi) where Hon’ble Delhi High Court held that where Assessing Officer after carrying out elaborate analysis and following steps enacted in statute, had determined amount of expenditure incurred for earning tax exempt income, merely because he did not expressly record his dissatisfaction about assessee's calculation, his conclusion could not be…

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5525/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…tion (2) shall also apply to a case where an assessee claims that ITA Nos. 5524 & 5525/Del/2013 no expenditure has been incurred by him in relation to exempt income.” 5.13 The Hon’ble Delhi High Court in the case of Indiabulls Financial Services Ltd Vs DCIT 395 ITR 292 (Delhi) that even an implied dissatisfaction on the claim of the disallowance under section 14A by the assessee is sufficient to meet the requirement of section 14A(2) of the Act. The relevant finding of the Hon’ble Delhi High Court is reproduced as under: “ 7. Undoubtedly, the language of Section 14A presupposes that the AO has to adduce some r…

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5524/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…tion (2) shall also apply to a case where an assessee claims that ITA Nos. 5524 & 5525/Del/2013 no expenditure has been incurred by him in relation to exempt income.” 5.13 The Hon’ble Delhi High Court in the case of Indiabulls Financial Services Ltd Vs DCIT 395 ITR 292 (Delhi) that even an implied dissatisfaction on the claim of the disallowance under section 14A by the assessee is sufficient to meet the requirement of section 14A(2) of the Act. The relevant finding of the Hon’ble Delhi High Court is reproduced as under: “ 7. Undoubtedly, the language of Section 14A presupposes that the AO has to adduce some r…

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5492/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…tion (2) shall also apply to a case where an assessee claims that ITA Nos. 5524 & 5525/Del/2013 no expenditure has been incurred by him in relation to exempt income.” 5.13 The Hon’ble Delhi High Court in the case of Indiabulls Financial Services Ltd Vs DCIT 395 ITR 292 (Delhi) that even an implied dissatisfaction on the claim of the disallowance under section 14A by the assessee is sufficient to meet the requirement of section 14A(2) of the Act. The relevant finding of the Hon’ble Delhi High Court is reproduced as under: “ 7. Undoubtedly, the language of Section 14A presupposes that the AO has to adduce some r…

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5491/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…tion (2) shall also apply to a case where an assessee claims that ITA Nos. 5524 & 5525/Del/2013 no expenditure has been incurred by him in relation to exempt income.” 5.13 The Hon’ble Delhi High Court in the case of Indiabulls Financial Services Ltd Vs DCIT 395 ITR 292 (Delhi) that even an implied dissatisfaction on the claim of the disallowance under section 14A by the assessee is sufficient to meet the requirement of section 14A(2) of the Act. The relevant finding of the Hon’ble Delhi High Court is reproduced as under: “ 7. Undoubtedly, the language of Section 14A presupposes that the AO has to adduce some r…

M/S MINDA INVESTMENT LTD.,,DELHI vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee are, accordingly, allowed

ITA 510/DEL/2017[2012-13]Status: DisposedITAT Delhi03 Sept 2019AY 2012-13

Bench: Shri Prashant Maharishi & Shrik.Narasimha Chary

For Appellant: Shri R.K. Kapoor, CAFor Respondent: Ms. Rinku Singh, Sr.DR
Section 10(34)Section 143(3)Section 14A

…dictional High Court, and to name a few, in the cases of UK Paints (India) (P) Ltd (2017) 392 ITR 552 (Delhi),Tariksha Engineering India Ltd (2015) 54 taxmann.com 109 (Delhi), HT Media Ltd vs. PCIT 399 ITR 576-Delhi, India Bulls Financial Services Ltd vs DCIT 395 ITR 242-Delhi etc., the Assessing Officer, in the first instance, must examine the disallowance made by the assessee or the claim of the assessee that only a particular amount was incurred as expenditure to earn the exempt income, and only if the AO is not satisfied on this count after making reference to the accounts, then only he would require jurisdic…

PR. COMMISSIONER OF INCOME TAX - 6 vs. MIS MODI RUBBER LTD.

ITA/260/2019HC Delhi02 Sept 2019

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Section 14Section 14ASection 14A(2)

…the dissatisfaction of the learned AO was not discernible while invoking Section 14 A of the Income Tax Act and needs a re-look in light of the decision of this Court in India Bulls Financial Services Private Limited v. Deputy Commissioner of Income Tax 2017 395 ITR 242 (Delhi). The operative part of the impugned order reads as follows:- 5.7 In view of the above decision of the Hon'ble Delhi High Court, we are of the opinion that in the instant case, the decision of the learned CIT(A) that dissatisfaction of the learned AO is not discernible, need a re-look and thus the issue needs to be re- examined by the le…

DCIT, NEW DELHI vs. M/S. HERO MOTOCORP LTD., NEW DELHI

In the result, appeal of the assessee is allowed in part for statistical purposes and appeal of the revenue is dismissed

ITA 5529/DEL/2014[2004-05]Status: DisposedITAT Delhi31 Jul 2019AY 2004-05

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: Shri Gaurav Jain , AdvocateFor Respondent: Shri Sanjay I. Bara, CIT- DR
Section 143(3)Section 14ASection 80

…roposition. 6. According to the learned DR, the reasons recorded by the learned AO are sufficient to comply with the requirement of Section 14A and in 4 view of the decision of Delhi High Court in the case of India Bulls Financial Services Ltd. vs DCIT (2017) 395 ITR 242 (Del),no particular format is required for such dissatisfaction. 7. We have gone through the record. At para 4.5, learned AO recorded that the assessee had simply stated that no expenditure was incurred on earning the exempt income and the same cannot be accepted because for earning the exempt income, there are various administrative expenses inv…