The Tax Publishers2021 TaxPub(DT) 2634 (Mum-Trib)

INCOME TAX ACT, 1961

Section 14A Rule 8D

Investment, which did not yield exempt income, was liable to be excluded for computation of average value of investments for the purpose of rule 8D(2).

Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D -

AO while assessing expenditure to earn exempt income under section 14A read with rule 8D(2) also considered non-exempt income bearing investments for computation of average value of investments. Held: Investment which did not yield exempt income was liable to be excluded for computation of average value of investments for the purpose of rule 8D(2).

Followed:ACIT v. Vireet Investment (P.) Ltd. (2017) 82 taxmann.com 415 (Del) : 2017 TaxPub(DT) 1760 (Del-Trib)

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2014-15


INCOME TAX ACT, 1961

Section 37(1) Section 40(a)(ii)

SUBSCRIBE TaxPublishers.inSUBSCRIBE FOR FULL CONTENT

TaxPublishers.in

'Kedarnath', 7, Avadh Vihar, Near Nirali Dhani,

Chopasni Road

Jodhpur - 342 008 (Rajasthan) INDIA

Phones : 9785602619 (11 am - 5 pm)

E-Mail : mail@taxpublishers.in / mail.taxpublishers@gmail.com