E.I.D. Parry India Ltd. v DCIT (2025) 235 TTJ 485 (Chennai)(Trib)

S.14A: Disallowance of expenditure-Exempt income-Interest expenditure-Disallowance has to be computed at 0.5 per cent of investments which have actually yielded exempt income during the year and not the average of investments as appearing in the balance sheet of the assessee.[R.8D(2)(iii)]

Held that the quantum of share capital, reserves and surplus of the assessee-company for the relevant year exceeds the investments which have resulted in exempt income; interest expenditure cannot be disallowed. Disallowance under R. 8D(2)(iii) has to be computed at 0.5 per cent of investments which have actually yielded exempt income during the year and not the average of investments as appearing in the balance sheet of the assessee. (AY. 2011-12 to 2014-15)

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