Bayer Crop Science Ltd. v Dy. CIT (2023) 156 taxmann.com 510 / / 226 TTJ 825 / (2024) 204 ITD 630 (Mum) (Trib.)

S. 14A : Disallowance of expenditure-Exempt income-Justified in computing disallowance under section 14A at 0.5 per cent of average value of investment.[ R.8D]

Held that where, 25 per cent of cost of Treasury Department for monitoring investment activities was considered for disallowance under section 14A by assessee, since investment decisions were generally taken in meetings of Board of Directors for which administrative expenses were incurred, by applying computation mechanism as provided under rule 8D(2)(iii), AO was justified in computing disallowance under section 14A at 0.5 per cent of average value of investment. (AY. 2009-10, 2012-13)