Held, that the Assessing Officer has to make disallowances based on the settled position of law that the disallowance under section 14A is to be restricted only to the extent of exempt income earned and the investments to be considered for making disallowances were only on those investments which had actually earned the dividend. The Assessing Officer was directed to re-work disallowance under section 14A under rule 8D(2)(iii) by adopting only those investments which had yielded exempt income. (AY. 2008-09 to 2012-13)
Crisil Ltd. v. Add. CIT (2024)112 ITR 56 (Mum)(Trib)
S.14A : Disallowance of expenditure-Exempt income-Disallowance is to be restricted to exempt income earned and only investments which had actually earned dividend to be considered for disallowance. [R.8D(2)(iii)]