Tribunal held that in the case of banks, investments that were held as stock in trade could not be a subject matter of disallowance and those investments which had not yielded any exempt income were not to be considered for the purpose of working out the disallowance. Relied on CIT v. Vireet Investment (P) Ltd. [2017 58 ITR (Trib) 313 (Delhi) [SB and Maxopp Investment Ltd. v. CIT [2018 402 ITR 640 (SC). (AY. 20011-12)
HDFC Bank Ltd. v. ACIT (2020) 82 ITR 533 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-Investments held as Stock In Trade cannot be subject matter of disallowance-Strategic investments yielding exempt income alone to be considered for purpose of working of disallowance. [R. 8D(2)(iii)].