TMI Blog2019 (7) TMI 1487X X X X Extracts X X X X X X X X Extracts X X X X ..... ssioner (Appeals) with regard to the computation of disallowance under section 8D(2)(iii) is fully in conformity with the ratio laid down in CIT v/s Vireet Investment Pvt. Ltd., [ 2017 (6) TMI 1124 - ITAT DELHI] wherein as held that while computing disallowance under rule 8D(2)(iii), only those investments which have yielded exempt income during the year under consideration can be considered. Tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts are, the assessee, as stated by the Assessing Officer, is a domestic company engaged in the business of investment in shares and securities. In the course of assessment proceedings, the Assessing Officer noticed that during the year under consideration, the assessee has earned exempt income by way of dividend amounting to ₹ 17,200. Therefore, he called upon the assessee to explain why ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5JB of the Act. Being aggrieved of such disallowance/addition, the assessee preferred appeal before the first appellate authority. 4. After considering the submissions of the assessee in the context of facts and material on record, learned Commissioner (Appeals) found that while deciding identical issue in case of assessee s holding company viz. Reliance Capital Ltd. for the A.Y. 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... omputing disallowance under rule 8D(2)(iii), only those investments which have yielded exempt income during the year under consideration can be considered. That being the case, we do not find any infirmity in the decision of the learned Commissioner (Appeals). Accordingly, grounds raised are dismissed. 6. In the result, Revenue s appeal is dismissed. Order pronounced ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
