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2022 (3) TMI 18 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - As argued assessee has not received dividend on certain shares and, therefore, no disallowance could be made u/s 14A in those shares on which no dividend has been received - HELD THAT:- It has been held in various decisions that for the purpose of computing disallowance u/s 14A r.w.r. 8D, the investments which has yielded dividend income are only to be considered. Since it is the submission of the ld. Counsel that it has received dividend income only in respect of six investments, the average investment of which comes to ₹ 16,55,49,405/-, therefore, we deem it proper to restore the issue to the file of the AO with a direction to recompute the disallowance u/s 14A r.w. Rule 8D by considering the investment which has actually yielded dividend income and exclude the investments on which the assessee has not received any dividend income in view of the decision in the case of ACIT vs. Vireet Investment Pvt. Ltd., [2017 (6) TMI 1124 - ITAT DELHI] and case of ACB India Ltd [2015 (4) TMI 224 - DELHI HIGH COURT] - Grounds raised by the assessee are accordingly allowed for statistical purposes.
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