Pragathi Krishna Gramin Bank. v. JCIT (2018) 256 Taxman 349 (Karn)(HC)

S. 14A : Disallowance of expenditure – Exempt income -Disallowance cannot be made in excess of actual exempted income-Matter remanded . [ R.8D ]

Allowing the appeal of the assessee the Court held that the ,AO as well as Appellate Authority disallowed expenses incurred by assessee bank in earning exempt income in excess to actual exempt income, same was per se absurd and hypothetical and therefore, matter was to be remanded back to AO.( AY.2011-12 )