| COURT: | ITAT Delhi |
| CORAM: | T. S. Kapoor (AM), U.B.S. Bedi (JM) |
| SECTION(S): | 14A, Rule 8D |
| GENRE: | Domestic Tax |
| CATCH WORDS: | exempt income, strategic investment |
| COUNSEL: | Ajay Vohra |
| DATE: | April 4, 2014 (Date of pronouncement) |
| DATE: | October 16, 2014 (Date of publication) |
| AY: | 2008-09 & 2009-10 |
| FILE: | Click here to download the file in pdf format |
| CITATION: | |
| No disallowance u/s 14A & Rule 8D can be made towards exempt income earned on strategic investments | |
The assessee had made significant investments in the shares of subsidiary companies which are definitely not for the purpose of earning exempt income. Strategic investment has to be excluded for the purpose of arriving at disallowance under Rule 8D(iii). The disallowance under Rule 8D(iii) has to be computed by excluding the value of strategic investments. No disallowance under Rule 8D(i) and 8D(ii) is also warranted (REI Agro (ITAT Kol) followed)
See also Oriental Structural Engineers (Del HC), Garware Wall Ropes (ITAT Mum), JM Financial (ITAT Mum) & EIH Associated Hotels (ITAT Chennai)
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