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| The Tax Publishers2020 TaxPub(DT) 3761 (Del-Trib) INCOME TAX ACT, 1961
Section 14A
Tribunal in the case of ACIT V. Vireet Investments Pvt. Ltd. 2017 TaxPub(DT) 1760 (Del-Trib) held that only those investments were to be considered for computing the average value of investment which have yielded exempt income during the year. Therefore, interests of justice would be well served by computing the disallowance @ 0.5% on the average investment only which had yielded the profits.
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Disallowance under section 14A - Expenditure incurred on exempted income - Only those investment which have yielded exempt income -
Assessee-company e-filed its return of income declaring total income and case was selected for scrutiny under CASS. After issue of statutory notices and hearings, returned income was accepted under section 143(3) by ACIT. Subsequently, PCIT, on perusal of Schedule 4 of the accounts noticed that during the year assessee had invested an amount and determined the disallowance an amount @ 0.5% in accordance with the provisions of Rule 8D(2)(iii) to Section 14A. Held: Tribunal in the case of ACIT v. Vireet Investments Pvt. Ltd. 2017 TaxPub(DT) 1760 (Del-Trib) held that only those investments were to be considered for computing the average value of investment which have yielded exempt income during the year. Therefore, interests of justice would be well served by computing the disallowance @ 0.5% on the average investment only which had yielded the profits.
Followed:ACIT v. Vireet Investment (P.) Ltd. 2017 TaxPub(DT) 1760 (Del-Trib)
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
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