Sec. 14A disallowance to be restricted to amount of exempt income only; SLP dismissed.
[2018] 99 taxmann.com 286 (SC)
SUPREME COURT OF INDIA
Principal Commissioner of Income Tax, Patiala.
vs.
State Bank of Patiala
Section 14A, read with section 263, of the Income-tax Act, 1961 – Expenditure incurred in relation to income not includible in total income (Computation of) – Assessment year 2010-11 – In course of assessment, Assessing Officer made addition on account of apportionment of expenses against exempted income under section 14A – Commissioner passed a revisional order directing Assessing Officer to enhance amount of addition under section 14A – Tribunal set aside revisional order as well as consequent assessment order passed by Assessing Officer enhancing addition made under section 14A – High Court upheld order of Tribunal holding that amount of disallowance under section 14A could be restricted to amount of exempt income only and not a higher figure – Whether on facts, SLP filed
against decision of High Court was to be dismissed – Held, yes [Para 1][In favour of assessee]