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2018 (3) TMI 662 - AT - Income TaxDisallowance made under section 14A r/w rule 8D(2)(iii) - Held that:- Investments not giving rise to exempt income during the relevant financial year have to be excluded from the average value of investment. We direct the Assessing Officer to verify the assessee’s claim that it has not received any exempt income on the aforesaid investments and if assessee’s claim is found to be correct, the aforesaid investment should be excluded from the average value of investment for computing disallowance under rule 8D(2)(iii). Grounds raised are allowed for statistical purposes. Addition of service tax to the trading receipt by invoking provisions of section 145A - Held that:- The Tribunal, while deciding identical issue in assessee’s own case for assessment year 2007–08 followed another decision of the same Bench, wherein, it is held that since the assessee is a service provider, the provisions of section 145A cannot be made applicable as such provisions were specifically introduced for the purpose of manufacture segment of business.
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