DCIT v. Edelweiss Commodities Services Ltd. (2021) 186 ITD 189 / 198 DTR 234 / 210 TTJ 914 (Mum.)(Trib.)

S.14A : Disallowance of expenditure-Exempt income-Net interest could be disallowed-Book Profit-Computation under clause (f) of Explanation 1 to section 115JB(2) is to be made without resorting to computation as contemplated under section 14A read with rule 8D. [S. 115JB, R. 8D]

Tribunal held that purpose of applying factors contained in clause (ii) of sub-rule (2) of rule 8D, prior to its amendment with effect from 2-6-2016, amount of expenditure by way of interest would be interest paid by assessee on borrowings minus taxable interest earned during financial year. Tribunal also held that for computation under clause (f) of Explanation 1 to section 115JB(2) is to be made without resorting to computation as contemplated under section 14A read with rule 8D. (AY. 2012-13)