Assessee made suo moto disallowance under Rule 8D. AO computed disallowance under rule 8D(2)(iii). For the calculation of average investments only those investments from which exempt income is derived. Assessee did not derive any exempt income matter remitted back to AO. (AY. 2012-13)
Cox & Kings Ltd. v. Addl. CIT (2019) 55 CCH 75/ 69 ITR 45 (SN) (Mum.) (Trib.)
S. 14A : Disallowance of expenditure-Exempt income–For the calculation of average investments only those investments from which exempt income is derived. Assessee did not derive any exempt income matter remitted back to AO. [R. 8D]