DCDC Health Services P. Ltd. v. ACIT (2023) 105 ITR 60 (Delhi) (Trib)

S. 14A : Disallowance of expenditure-Exempt income-No fresh investments towards mutual funds made in current year-Disallowance is not valid. [R.8D]

Held that as the investment in mutual funds which yielded dividend income were made out of non-interest bearing funds in the financial year 2014-15 and no fresh investments towards mutual funds were made in the financial year 2015-16, the disallowance under section 14A read with rule 8D(2)(ii) of the Rules was not sustainable for the year under consideration. (AY. 2016-17)