The assessee computed disallowance under section 14A on an ad hoc basis by allocating a portion of treasury department expenses. The Assessing Officer applied Rule 8D(2)(iii) and computed disallowance at 0.5 per cent. of the average value of investments after observing that administrative resources, including the Board of Directors, were involved in investment decisions. The Tribunal held that the assessee had failed to demonstrate that no administrative expenditure was attributable to earning exempt income. Accordingly, the disallowance computed by the Assessing Officer under Rule 8D was upheld. (AY. 2009-10, 2012-13).