The Tax Publishers2022 TaxPub(DT) 1512 (Pune-Trib)

INCOME TAX ACT, 1961

Section 14A Rule 8D(2)(ii)

Only those investments should be considered for computing average value of investments under rule 8D which yielded exempt income during the year under consideration.

Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D(2)(iii) -

Assessee earned tax free dividend income on investments in shares. AO while computing disallowance under section 14A considered non-dividend bearing investments also for determination of average value of investments. Held:/i> Only those investments should be considered for computing average value of investments under rule 8D which yielded exempt income during the year under consideration. AO was directed accordingly.

Relied:Vireet Investments (P) Ltd. (2017) 165 ITD 27 (Del-Trib) (SB) : 2017 TaxPub(DT) 1760 (Del-Trib).

REFERRED :

FAVOUR : Matter remanded.

A.Y. : 2013-14


INCOME TAX ACT, 1961

Section 32(1)(iia)

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