Pricewaterhouse Coopers (P.) Ltd. v. ACIT (2020) 183 ITD 354 (Kol.)(Trib.)

S. 14A : Disallowance of expenditure-Exempt income-Disallowance under Rule 8D(2)(iii) is to be done by taking into account dividend bearing securities only. [S. 10(34), R.8D(2)(iii)]

The assessee has voluntarily disallowed a sum of Rs.30,000 under section 14A in computation of total income. The AO disallowed Rs.49.35 lakhs. DRP held that only such investments in respect of which dividend income or exempted income has been earned can be considered when computing disallowance. On appeal the Tribunal directed the Assessing Officer to compute disallowance under Rule 8D(2)(iii) by taking into account dividend bearing securities only. (AY. 2014-15)