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| The Tax Publishers2020 TaxPub(DT) 2793 (Kol-Trib) INCOME TAX ACT, 1961
Section 14A
Since entire investment in shares was made by assessee out of her own funds and it was observed that said position was accepted by AO as well as by CIT(A), thus, disallowance made on account of interest under section 14A as worked out by applying rule 8D(2)(ii) was not sustainable.
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Disallowance under section 14A - Expenditure against exempt income - Investment in shares was made by assessee out of her own funds -
Issue was as regards disallowance under section 14A read with rule 8D(ii). Held: Entire investment in shares was made by assessee out of her own funds and it was observed that said position was accepted by AO as well as by CIT(A) thus disallowance made on account of interest under section 14A as worked out by applying rule 8D(2)(ii) was not sustainable.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 14A
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