The Tax Publishers2020 TaxPub(DT) 4624 (Mum-Trib)

INCOME TAX ACT, 1961

Section 14A

Average value of investments for the purpose of rule 8D(2)(iii) was to be computed considering only those investments which had actually earned dividend/exempt income.

Disallowance under section 14A - Expenditure against exempt income - Invocation of rule 8D(2)(iii) - AO considered non-exempt income bearing investments also

Assessee earned tax free dividend income on investments in shares. AO invoked rule 8D(2)(iii) and made disallowance under section 14A considering non-exempt income bearing investments also.Held: Average value of investments for the purpose of rule 8D(2)(iii) was to be computed considering only those investments which had actually earned dividend/exempt income.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2012-13


INCOME TAX ACT, 1961

Section 194H

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