Tata Steel Ltd. v. Dy. CIT (2024)109 ITR 18 (Mum) (Trib)

S.14A : Disallowance of expenditure-Exempt income – Suo motu disallowance-Additional disallowance cannot be made by general remarks without satisfying himself as to correctness of disallowance – Addition is deleted.[R.8D]

Held that the Assessing Officer had made general remarks, such as how investments could not be managed without monitoring and research. This approach of the Assessing Officer completely overlooking the detailed analysis and allocation of the assessee and without examining them could not be upheld. It is imperative that the Assessing Officer record his satisfaction on the claim made by the assessee having regard to the accounts. It was also seen that about ninety-seven per cent. of the investments were made in group companies as strategic investments. Thus, the remarks of the Assessing Officer that expenses are incurred on market research were not applicable on the facts of the case. The disallowance was deleted. (AY.2019-20)

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