Dell International Services India (P.) Ltd. v. JCIT (2022) 94 ITR 247 (Bang.)(Trib.)

S. 14A : Disallowance of expenditure-Exempt income-Only those investments, which have yielded exempt income has to be considered for the purpose of computing average value of investments for computing the disallowance. [R.8D]

Tribunal placing reliance on order of Special Bench of the Tribunal in the case of ACIT v. Vireet Investment Pvt. Ltd. (ITAT Delhi-SB), held that only those investments, which have yielded exempt income has to be considered for the purpose of computing average value of investments for computing disallowance under, rule 8D.  (AY. 2009-10)