Dismissing the appeal of the Revenue the Court held that where shares were held by assessee-bank as stock-in-trade and not as investment, main purpose was to trade in those shares and earn profits therefrom and therefore section 14A was not attracted and expenditure could not be disallowed (AY. 2010-11)
PCIT v. Punjab National Bank (2022) 449 ITR 468 / 288 Taxman 127 (Delhi)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Bank-Shares held as stock in trade-No disallowance of expenditure could be made. [R. 8D]