The Tax Publishers2020 TaxPub(DT) 0298 (Del-Trib)

INCOME TAX ACT, 1961

Section 14A

Only investments which yielded exempt income had to be considered to workout average value of investment for the purpose of disallowance of expenditure under rule 8D.

Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D - AO considered all the investments to work out average value of investments

Assessee earned tax free dividend income on certain investment in shares. AO invoked rule 8D and considered all the investments for computation of average value of investments.Held: Only investments which yielded exempt income had to be considered to workout average value of investment for the purpose of disallowance of expenditure under rule 8D.

Followed:CIT v. Inter Global Enterprises Ltd. [ITA 456/2016, dt. 19-8-2016].

REFERRED :

FAVOUR : Partly in assessee's favour.

A.Y. : 2008-09


INCOME TAX ACT, 1961

Section 194J

SUBSCRIBE TaxPublishers.inSUBSCRIBE FOR FULL CONTENT