| |
| The Tax Publishers2020 TaxPub(DT) 0750 (Chd-Trib) INCOME TAX ACT, 1961
Section 14A
Where own funds/interest free funds were available with assessee to meet investment then, presumption would be that assessee had used its own/interest-free funds for making concerned investment and, therefore, no interest expenditure disallowance under section 14A read with rule 8D(2)(ii) was called for.
|
Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D(2)(ii) - Interest expenditure--Assessee having sufficient own funds
Assessee earned tax free dividend income on investment. AO invoked section 14A read with rule 8D(2)(ii) and made disallowance on account of proportionate interest income.Held: Own funds/interest free funds were available with assessee to meet investment therefore, presumption would be that assessee had used its own/interest free funds for making concerned investment and, therefore, no interest expenditure disallowance under section 14A read with rule 8D(2)(ii) was called for.
Relied:CIT (LTU) v. Reliance Industries Ltd.' (2019) 410 ITR 466 (SC) : 2019 TaxPub(DT) 0659 (SC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 14A
 SUBSCRIBE FOR FULL CONTENT
|