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2021 (2) TMI 631 - AT - Income TaxAddition u/s 14A r.w.r. 8D - Disallowance made on the entire investments - HELD THAT:- We observe that Rule 8D(2)(iii) is clear that disallowance should be made under the said rule on those investments, on which the assessee earns exempt income, but, not on the entire investments. In this connection, we refer to the decision in the case of Transport Corporation of India Ltd. [2016 (11) TMI 245 - ITAT HYDERABAD] wherein directed to calculate the disallowance of expenditure under rule 8D(2)(iii) taking the average investment from which the exempt income is received. Following the above decision, we direct the AO to calculate the disallowance under rule 8D(2)(iii) in line with the above decision. The assessee is directed not to take any unnecessary adjournments for early disposal of the appeal. Needless to say that reasonable opportunity may be given to the assessee Accordingly, the grounds raised by the assessee in this regard are treated as allowed for statistical purposes.
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