Dismissing the appeal of the revenue the Court held that rule 8D could not be applied blindly when the assessee had hardly incurred any expenses in respect of the dividend earned and substantial investments were made temporarily in order to invest idle funds.
PCIT v. Lee and Muirhead Pvt. Ltd. (2020)423 ITR 167 (Bom) (HC)
S. 14A : Disallowance of expenditure – Exempt income – No expenditure was incurred – Disallowances cannot be made . [ R.8D ]