Held that rule 8D, could be applied only in respect of investment which actually yielded dividend income during year. Therefore, Commissioner (Appeals) rightly directed Assessing Officer to recompute disallowance under section 14A in accordance with Rule 8D only with reference to investments which actually yielded dividend income during year. (AY. 2008-09)
Himatsingka Seide Ltd. v. DCIT (2024) 206 ITD 371 (Kol.)(Trib.)
S.14A : Disallowance of expenditure-Exempt income-Rule 8D can be applied only in respect of investment which actually yielded dividend income during year. [R.8D]