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    <title>2014 (4) TMI 269 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=245798</link>
    <description>ITAT Delhi held that no disallowance under Rule 8D(i) and 8D(ii) was warranted as the assessee used interest-free funds for investments in subsidiaries for strategic purposes, not to earn exempt income, and incurred no direct or indirect interest expenditure. Regarding Rule 8D(iii), the tribunal found that certain mutual fund investments were merely parking of surplus funds and not genuine investments for earning exempt income. The AO&#039;s disallowance calculation was incorrect for including total investments instead of only those made to earn exempt income. The tribunal directed the AO to exclude strategic investments in subsidiaries from the disallowance calculation under Rule 8D(iii). The decision was partly in favor of the assessee.</description>
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    <pubDate>Fri, 04 Apr 2014 00:00:00 +0530</pubDate>
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      <title>2014 (4) TMI 269 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=245798</link>
      <description>ITAT Delhi held that no disallowance under Rule 8D(i) and 8D(ii) was warranted as the assessee used interest-free funds for investments in subsidiaries for strategic purposes, not to earn exempt income, and incurred no direct or indirect interest expenditure. Regarding Rule 8D(iii), the tribunal found that certain mutual fund investments were merely parking of surplus funds and not genuine investments for earning exempt income. The AO&#039;s disallowance calculation was incorrect for including total investments instead of only those made to earn exempt income. The tribunal directed the AO to exclude strategic investments in subsidiaries from the disallowance calculation under Rule 8D(iii). The decision was partly in favor of the assessee.</description>
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      <pubDate>Fri, 04 Apr 2014 00:00:00 +0530</pubDate>
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