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2019 (5) TMI 992 - AT - Income TaxDisallowance u/s 14A - investments as made in investments in units and shares which generates tax-free income - HELD THAT:- The contention of the assessee that it has made investments in subsidiary companies/strategic investments and hence section 14A will not be applicable, lacks merit keeping in view decision in the case of Maxopp Investments Limited v. CIT [2018 (3) TMI 805 - SUPREME COURT] and hence this contention of the assessee stood rejected. Only those investments which actually yielded tax-free income shall be considered for computing disallowance u/s 14A read with Rule 8D(2)(iii) of the 1962 Rules, keeping in view decision of Special Bench of ITAT, Delhi in the case of Vireet Investments Private Limited [2017 (6) TMI 1124 - ITAT DELHI] and AO is accordingly directed in above lines to recomputed disallowance u/s 14A of the 1961 Act read with Rule 8D(2)(iii) of the 1962 Rules. - Appeal of the assessee is partly allowed.
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