Rampgreen Solutions P. Ltd. v. Dy. CIT (2023)108 ITR 392 (Delhi)(Trib) Dy. CIT v. CLP India.P. Ltd (2023) 108 ITR 248 (Ahd)(Trib)

S.14A : Disallowance of expenditure-Exempt income-Investments not yielding exempt income to be excluded in computing disallowance — Disallowance to be restricted to exempt income earned.[R.8D]

Held that with respect to the disallowance under section 14A of the Act read with rule 8D(2)(iii) of the Rules, there was no infirmity in the directions of the Dispute Resolution Panel to exclude those investments which did not yield exempt income for the purpose of the computation of the disallowance and to restrict the disallowance only to the dividend income earned.(AY.2011-12)