Income Tax Act, 1962

Section 14A Rule 8D(iii)

Disallowance under section 14A - Expenditure against exempt income - Administrative expenses under rule 8D(2)(iii) - AO considered non-dividend yielding investments also for computation of average value of investments

AO while computing disallowance under section 14A read with rule 8D(2)(iii) considered non-dividend yielding investments also for computation of average value of investments. Held: Only those investments, which yielded exempt income during the year, were to be considered for computing average value of investment for the purpose of disallowance under rule 8D(2)(iii).

Followed:ACIT v. Vireet Investment v. ACIT (2017) 165 ITD 27 (Delhi-Trib SB) : 2017 TaxPub(DT) 1760 (Del-Trib).

REFERRED :

FAVOUR : Partly in assessee's favour

A.Y. : 2015-16

INCOME TAX ACT, 1961

Section 253(4)

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