TMI Blog2019 (12) TMI 1302X X X X Extracts X X X X X X X X Extracts X X X X ..... t average value of investment which yielded exempt income during the year only shall be considered for the purpose of disallowance u/s 14A. Since the CIT(A) has given a categorical finding that the assessee has received dividend income of ₹ 6,48,431/- from the current investment of ₹ 11,02,496/-, therefore, 0.5% of the above investment has to be treated as expenses incurred for earn ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd on facts in restricting the addition to ₹ 5512/- as against ₹ 1,79,74,266/- made by the AO on account of disallowance u/s 14A r.w.r. 8D of Income Tax Rules. 2. The appellant craves leave for reserving the right to amend, modify, alter, add or forego any ground (s) of appeal at any time before or during the hearing of this appeal. 3. The facts of the case are that the Assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Vireet Investment Pvt. Ltd. and Anr. (2017) 165 ITD 0027 (Del) (SB), held that average value of investment which yielded exempt income during the year only shall be considered for the purpose of disallowance u/s 14A. Since the ld.CIT(A) has given a categorical finding that the assessee has received dividend income of ₹ 6,48,431/- from the current investment of ₹ 11,02,496/-, therefore ..... X X X X Extracts X X X X X X X X Extracts X X X X
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