Shriram Transport Finance Co. Ltd. v. ITO (OSD) (2024)460 ITR 66 (Mad)(HC)

S.14A : Disallowance of expenditure-Exempt income-No reasons recorded-Order of Tribunal is affirmed.[R. 8D]

Held that  the Assessing Officer made disallowances under section 14A read with rule 8D, but there was no reason recorded by him, as to why he was not satisfied with the claim made by the assessees. Further, there was no examination by the Assessing Officer about the nature of investment by the assessees in their subsidiary companies and expenditure incurred by them. The Commissioner (Appeals) and the Tribunal had pointed out certain errors committed by the Assessing Officer, accepted the contentions raised by the assessees and directed the Assessing Officer to modify the disallowances under section 14A. Such course adopted by the appellate authorities was justified..(AY.2003-04 to 2014-15)