Abusha Investment & Management Services LLP vs. DCIT

Parties Involved

Facts Summary

The appeal by the assessee, Abusha Investment & Management Services LLP, pertains to the disallowance of Rs.403.78 Lacs under Section 14A for the Assessment Year 2018-19. The assessee had received a dividend of Rs.80.15 Lacs and claimed Rs.10 Lacs as exempt. The Assessing Officer (AO) computed the disallowance under Rule 8D, resulting in an addition of Rs.403.78 Lacs to the assessee's income. The Commissioner of Income Tax (Appeals) confirmed this addition, leading to the assessee's appeal. The assessee argued that the dividend income was taxable under Section 115BBDA and that the AO erred in computing the disallowance. The Senior Deputy Revenue (Sr. DR) justified the addition, citing Section 115BBDA (2) which disallows expenditure in computing income by way of dividend. The tribunal heard both sides and reviewed the case records.…

Legal Issues

• 1. Whether the disallowance of Rs.403.78 Lacs under Section 14A is justified.

Judgment Outcome

Decided in favour of Assessee.

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