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| The Tax Publishers2019 TaxPub(DT) 5060 (Pune-Trib) INCOME TAX ACT, 1961
Section 14A
While computing disallowance under rule 8D(2)(iii) only those investments on which assessee has earned dividend income had to be considerea for computing average value of investment.
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Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D(2)(iii) - Computation of average value of investments--Total investment v. tax and free income yielding investments
Assessee earned tax-free dividend income and made suo moto disallowance under section 14A. AO invoked rule 8D(2)(iii) and while computing average investments considered all the investments including investments on which no dividend income was earned by assessee. Held: While computing disallowance under rule 8D(2)(iii) only those investments on which assessee has earned dividend income had to be considered for computing average value of investment.
Relied:Asstt. CIT & Anr. v. Vireet Investment (P)Ltd. & Anr. (2017) 165 ITD 27 (Del) : 2017 TaxPub(DT0 1760 (Del-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2009-10
INCOME TAX ACT, 1961
Section 32(1)
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