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2022 (6) TMI 115

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..... urt in ACB India Ltd.[ 2015 (4) TMI 224 - DELHI HIGH COURT] has held that the average value of investments, for the purposes of Rule 8D(2)(iii), should be confined to those securities in respect of which exempt income is earned and not the total investments. Similar view has been taken by the Special Bench of the Tribunal in the case of ACIT vs. Vireet Investments (P) Ltd. [ 2017 (6) TMI 1124 - I .....

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..... 013-14. 2. The only issue raised in this appeal is against the disallowance u/s. 14A of the Income-tax Act, 1961 (hereinafter also called 'the Act'). 3. Briefly stated, the facts of the case are that the assessee earned exempt - dividend and long term capital gain - to the tune of Rs. 89.02 lakh. A sum of Rs. 29,536/- was shown as attributable to the exempt income and hence disallowa .....

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..... e average value of investments, for the purposes of Rule 8D(2)(iii), should be confined to those securities in respect of which exempt income is earned and not the total investments. Similar view has been taken by the Special Bench of the Tribunal in the case of ACIT vs. Vireet Investments (P) Ltd. (2017) 165 ITD 27 (Del) (SB). In view of the afore referred precedents, we set aside the impugned or .....

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