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| The Tax Publishers2019 TaxPub(DT) 0126 (Bang-Trib) INCOME TAX ACT, 1961
Section 14A
Only those investments were to be considered for computing average value of investment which yielded exempt income during the year under consideration for working out the disallowance under section 14A read with rule 8D(2)(iii).
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Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D - Computation of average value of investments
Assessee earned tax-free dividend income and claimed voluntary disallowance under section 14A. AO not satisfied with assessee's claim invoked rule 8D and also considered investment not having yielded tax-free income so as to compute average value of investments under rule 9D(2)(iii).Held: Only those investments were to be considered for computing average value of investment which yielded exempt income during the year under consideration for working out the disallowance under section 14A read with rule 8D(2)(iii).
Relied:Asstt. CIT v. Vireet Investments (P) Ltd. (2017) 82 Taxmann.com 415 (Del-Trib) (SB) : 2017 TaxPub(DT) 1760 (Del-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
IN THE ITAT, BANGALORE BENCH
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