Dismissing the appeal of the Revenue the Court held that  the Tribunal had not found, as a matter of fact, that the assessee had devoted any of its resources or had otherwise incurred any expenditure for managing the investments. The assessee’s assertion, that its investment was monitored by a group company without levying any charge or fee, was not found to be incorrect. In the circumstances, the Tribunal did not accept the Assessing Officer’s determination of Rs. 8,53,916 as expenditure incurred for earning the exempt income. Once the Revenue authorities have found no reason to doubt the assessee’s claim that the investments had been managed by a group company without levy of charge, it may not be open for the Tribunal to hold that the deployment of manpower for monitoring the dividends from mutual funds could not be ruled out. However, the assessee not having appealed against its decision no question of law arose. (AY. 2009-10)