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The Tax PublishersITA No. 1718/Kol/2017
2019 TaxPub(DT) 6223 (Kol-Trib)INCOME TAX ACT, 1961
Section 14A Rule 8D
Assessee had its own funds which were sufficient to meet investment, therefore, disallwoance under rule 8D(2)(ii) was not called for so far rule 8D(2)(iii) was concerned, AO was directed to compute disallowance considering dividend bearing investments only while calculating average value of investments.
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Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D - Assessee having sufficient own funds
Assessee earned tax freed income on investments. Accordingly, AO invoked section 14A read with rule 8D and worked out disallownace.Held: Assessee had its own funds which were sufficient to meet investment, therefore, disallwoance under rule 8D(2)(ii) was not called for so far rule 8D(2)(iii) was concerned, AO was directed to compute disallowance considering dividend bearing investments only while calculating average value of investments.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 145A
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