TMI Blog2016 (5) TMI 1533X X X X Extracts X X X X X X X X Extracts X X X X ..... empted income - as per AR no expenditure was incurred for earning the exempted income - HELD THAT:- It is nobody s case that the assessee has borrowed any loan for the purpose of making investment, therefore, the first limb of Rule 8D may not be applicable. No material is available on record to suggest that the assessee has incurred any interest expenditure which are not directly attributable to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A.No.1563/Mds/2015 - - - Dated:- 12-5-2016 - Shri N.R.S. Ganesan, Judicial Member And Shri A. Mohan Alankamony, Accountant Member Appellant by : Shri A. Vasudevan, CA Respondent by : Shri A.V Sreekanth, JCIT ORDER N.R.S.Ganesan, This appeal of the assessee is directed against the order of the Commissioner of Income-tax (Appeals)-1, Chennai, dated 24.3.2015 and pertains t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d, therefore, the Assessing Officer is not justified in making the disallowance. 4. On the contrary, Shri A.V. Sreekanth, ld. Departmental Representative submitted that Rule 8D provides for disallowance of expenditure relatable to earning the exempted income. In the case before us, according to the ld. DR, the assessee earned income which was exempted from tax, therefore, the expenditure incurr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee has borrowed any loan for the purpose of making investment, therefore, the first limb of Rule 8D may not be applicable. No material is available on record to suggest that the assessee has incurred any interest expenditure which are not directly attributable to any particular income or receipt. Therefore, the second limb of Rule 8D is also not applicable. Now coming to third limb of Rule 8D, an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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