PCIT v. Shalimar Pellet Feeds Ltd. (2022) 287 Taxman 134/213 DTR 345/326 CTR 595 / (2023)453 ITR 547 (Cal.)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Only those shares which had yielded dividend income in year under consideration to be considered [R. 8D].

Held that  machinery provision under rule 8D could be applied only with regard to shares which yielded dividend income in year under consideration. Order of Tribunal affirmed. (AY. 2011-12 to 2013-14)