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2018 (2) TMI 1581 - AT - Income TaxDisallowance u/s 14A R.w.r. 8D - Held that:- In this case the direct expenditure of ₹ 82,000/-has been admittedly incurred on demat accounts, which is evidently toward earning exempt income. Since in this case exempt income is only of ₹ 10,000/-, applying the decision of the Hon’ble Delhi High Court in the case of Joint Investment Private Limited (2015 (3) TMI 155 - DELHI HIGH COURT) would not be appropriate as in that case the assessee itself volunteered for disallowance of ₹ 2, 97, 440/-as attributable under section 14A of the Act, but in the instant case assessee has not attributed any expenses toward earning the exempt income, even the direct expenditure of ₹ 82,000/-on demat accounts Respectfully following the finding of the Tribunal in case of Vireet Investment Private Limited (2017 (6) TMI 1124 - ITAT DELHI), we restore the matter to the file of the Assessing Officer with the direction to consider only the investment which yielded exempt income, for the purpose of average value of investment while computing the disallowance under section 14A of the Act read with Rule 8D of Income-tax Rules, 1962.
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