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2017 (2) TMI 285 - AT - Income TaxAddition u/s 14A r.w.r. 8D - AO has taken into account the shares which were held as stock in trade and on which no dividend income was earned in making disallowance - Held that:- Assessee is a broker at the BSE and the NSE and is engaged in the business of share broking, investing and trading in shares and securities, mutual fund distribution, arbitrage activity on equity and derivative segment, providing financial consultancy services. In view of the decision of India Advantage Securities Limited [2012 (11) TMI 458 - ITAT, MUMBAI] direct the AO to exclude the shares held as stock in trade. Strategic investments made in the sister concerns/group companies - Held that:- Direct the A.O. to exclude the investments made in foreign subsidiaries and investment made in companies which are strategic in nature while computing the disallowance u/s 14A of the Act in respect of administrative expenses. See Kotak Mahindra Capital Company Limited Versus DCIT [2015 (1) TMI 1289 - ITAT MUMBAI ] Investment made in the immovable property also does not earn any exempt income. Accordingly, direct the AO to exclude the investment in the immovable property while computing disallowance under Rule 8D.
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