The Tribunal held that the assessee could not claim that provisions of section 14A could not be invoked because it had surrendered its right over claiming deduction under section 10(34) in respect of dividend income earned on shares. However, in view of fact that assessee had claimed that it had not incurred any expenses to earn exempt dividend income as investment had been made out of its own funds in 100 per cent subsidiary company, matter was to be remanded back for disposal afresh after taking into consideration aforesaid plea of assessee. (AY. 2013-14)
BBR Projects (P.) Ltd. v. ITO (2020) 184 ITD 842 (Hyd.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-Surrender of right to claim exemption-Matter remanded. [S. 10(34)]