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

S. 14A : Disallowance of expenditure-Exempt income-Short term borrowings-Equity shares held as stock in trade-portion of interest expenses related to earning of exempt dividend income had to be disallowed-Matter remanded-Method of valuation-Stock in trade-Matter remanded. [RR. 8D]

Tribunal held that where the assessee paid interest on short-term borrowings for equity shares held as a stock-in-trade and claimed dividend income from same as exempt, entire interest expenditure corresponding to stock-in-trade could not be allowed to assessee as business expenditure, portion of interest expenses related to earning of exempt dividend income had to be disallowed. Matter remanded.Tribunal held that it was not clear, whether provision for diminution in value of stock-in-trade had been made out of trading account or within trading account, matter was to be remanded back to Assessing Officer for adjudication afresh. (AY. 2012-13)