| |
The Tax PublishersITA No. 2122/Kol/2017
2019 TaxPub(DT) 2945 (Kol-Trib)INCOME TAX ACT, 1961
Section 14A
While computing disallowance under section 14A read with rule 8D(2)(iii), only those investments which have yielded exempt income during the year under consideration can be considered.
|
Disallowance under section 14A - No expenditure against exempt income - Only investment yielded exempt income to be considered -
Assessee earned exempt dividend income during the relevant assessment year. AO made addition under section 14A read with rule 8D(2)(iii) towards administrative expenses. CIT(A) directed AO to compute disallowance under rule 8D(2)(iii) by taking into account only those investments on which assessee had received exempt income during the year. Held: While computing disallowance under rule 8D(2)(iii), only those investments which have yielded exempt income during the year under consideration can be considered. Accordingly, there was no infirmity in the decision of CIT(A) warranting interference.
Followed:Rei Agro Ltd. v. Dy. CIT (2013) 144 ITD 141 (Kol) : 2013 TaxPub(DT) 2256 (Kol-Trib)
REFERRED :
FAVOUR : in assessee's favour
A.Y. :
 SUBSCRIBE FOR FULL CONTENT
|