ACIT v. PNB Gilts Ltd. (2020) 81 ITR 224 / 183 ITD 111 (Delhi) (Trib.)

S. 14A : Disallowance of expenditure-Exempt income-Investment from interest free own funds-No disallowance can be made. [R. 8D(2)(ii)]

Dismissing the appeal of the revenue the Tribunal held that on the facts of the case  the assessee received dividend income from investment including shares which were held as stock-in-trade, if entire investment in assets yielding exempt income had been made out of interest free own funds, then no disallowance would be called for under rule 8D(2)(ii) of the Rules.  (AY. 2012-13)