Thursday, 16 October 2014

No disallowance u/s 14A & Rule 8D can be made towards exempt= income earned on strategic investments

Interglobe Enterprises Ltd vs. DCIT (= ITAT Delhi)




The assessee had made significant investments in the shares of subsidia= ry companies which are definitely not for the purpose of earning exempt in= come. Strategic investment has to be excluded for the purpose of arriving = at disallowance under Rule 8D(iii). The disallowance under Rule 8D(iii) ha= s to be computed by excluding the value of strategic investments. No disal= lowance under Rule 8D(i) and 8D(ii) is also warranted (REI Agro (ITAT Kol) followed)

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