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2019 (5) TMI 1379 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - Appellant Company has suo motto disallowed towards such expenditure - Whether while computing the disallowance under section 14A rule 8D2(iii) of the Act, only those investments are required to be included for the purpose of calculating the average investments which yield exempt income during the year? - HELD THAT:- We find merit in the submissions of the Ld. A.R. and that only those investments yielding exempt income has to be considered for calculating the average investments. The issue is squarely covered by the decision of Tribunal in the case of ACIT vs. Vireet Investments [2017 (6) TMI 1124 - ITAT DELHI] wherein it has been held that only those investments are to be considered for computing average value of investments which yielded exempt income during the year. We, therefore, respectfully following the co-ordinate bench of the Tribunal, direct the AO to compute the disallowance after taking into account only those investments which yielded exempt income and for the purpose of average investment.
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