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| The Tax Publishers2019 TaxPub(DT) 4526 (Bang-Trib) INCOME TAX ACT, 1961
Section 14A
Where for the purpose of calculation of disallowance under rule 8D, only those investments which yielded exempt income have to be considered, therefore, matter was remanded back to AO to recompute the disallowance where only dividend yielding investment had to be considered for the purpose of calculation of average value of investments under rule 8D(2)(iii).
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Disallowance under section 14A - Assessee not incurred any expenditure for earning dividend income - Computation of -
Assessee had earned exempt dividend income whereas no expenses have been disallowed by the assessee for earning of such income. AO applied the provisions of section 14A read with section rule 8D(2)(iii) and calculated ½% of average investments. CIT(A) upheld the addition made by AO. Held: Tribunal in the case of Vireet Investments (2017) 58 ITR (Trib) 313 (Del) : 2017 TaxPub(DT) 1760 (Del-Trib) had held that where for the purpose of calculation of disallowance under rule 8D, only those investments which yielded exempt income have to be considered. Therefore matter was remanded back to AO to recompute the disallowance where only dividend yielding investment has to be considered for the purpose of calculation of average value of investments under rule 8D(2)(iii).
Followed:Asstt. CIT, Circle 17 (1), New Delhi v. Vireet Investment (P) Ltd. (2017) 58 ITR (Trib) 313 (Del) : 2017 TaxPub(DT) 1760 (Del-Trib)
REFERRED :
FAVOUR : In assessee's favour (by way of remand)
A.Y. :
INCOME TAX ACT, 1961
Section 10A
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