Tribunal held that the foreign investments on which dividend suffered taxation in India, no disallowance can be made . Similarly investments in Indian companies which not yielding exempt income, has to be excluded . Matter remanded to the Assessing Officer
Pentamedia Graphics Ltd. v. Dy. CIT (2020) 80 ITR 555 / 185 ITD 145/ 205 TTJ 892 (Chennai) (Trib)
S. 14A : Disallowance of expenditure – Exempt income -Foreign investments- Dividend suffered taxation in India – No disallowance can be made – Investments in Indian companies not yielding exempt Income —Has to be excluded . [ R.8D(iii) ]