ACIT v. Doshion Veolia Water Solution (P.) Ltd. (2025) 128 ITR 128 (Mum) (Trib.) ACIT v. Doshion Water Solution P. Ltd (2025) 128 ITR 128 (Mum) (Trib.)

S.14A: Disallowance of expenditure-Exempt income-Expenditure incurred in relation to income not includible in total income-Assessee’s own funds were much higher than investments that yield exempt income-Addition was deleted. [S.10(34), R.8D(2)(ii)]

The assessee received a dividend which was claimed exempt under section 10(34). The AO had made an addition under section 14A on account of interest expenditure by resorting to rule 8D(2)(ii). On the revenue’s appeal, ITAT held that as the assessee’s own funds were much higher than investments that yield exempt income, CIT(A) had rightly deleted the addition on account of interest expenditure under section 14A read with rule 8D(2)(ii). [AY. 2009-10, 2012-13]

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