The Court held that the provisions of section 14A, read with Rule 8D, were not applicable to shares held as stock‑in‑trade. It also affirmed that no disallowance of interest under section 14A was warranted since the assessee’s own interest‑free funds were greater than its investments in tax‑free securities. (AY. 2008‑09)
PCIT v. DSP Merill Lynch Capital Ltd. [2022] 142 taxmann.com 579 (Bom.)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Shares held as stock‑in‑trade excluded from Rule 8D; no disallowance where assessee’s own funds exceed tax‑free investments. [R. 8D]
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