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2014 (9) TMI 207 - PUNJAB & HARYANA HIGH COURT
Invocation of section 14A r.w Rule 8D – Expenses incurred on earning exempt income or not - Taxability of dividend income and LTCG – Held that:- The Tribunal has rightly held that the expenditure relatable to the earning of exempt income is equal to aggregate of the amount of expenditure directly relatable to the income which does not form part of the total income i.e. Rule 8D(2)(i) and the disallowance of interest as provided under Rule 8D(2)(ii) and further disallowance computed under Rule 8D(2)(iii) of the Income Tax Rules - the assessee had paid total interest out of which interest paid on term loan raised for specific purpose and balance interest paid by the assessee - after examining the balance-sheet of the assessee, a finding of fact has been recorded that the funds utilized by the assessee being mixed funds, therefore, the interest paid by the assessee is also an interest on the investments made – no substantial question of law arises for consideration – Decided against assessee.