https://www.taxtmi.com/caselaws?id=248281 The HC upheld the Tribunal's bifurcation of expenses under section 14A read with Rule 8D, ruling that the assessee did not incur any actual expenditure to earn tax-free income of Rs. 14 crores. The court found that the assessee used its own interest-free funds for investments and did not rely on borrowed funds. The Tribunal correctly excluded dividend income from foreign subsidiaries, which is taxable, from disallowance. The 1% disallowance of interest expenditure was rejected as it was based on assumption rather than fact. The decision was rendered against Revenue. en-us Tue, 04 Feb 2014 00:00:00 +0530 Thu, 31 Jul 2025 16:44:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248281 The HC upheld the Tribunal's bifurcation of expenses under section 14A read with Rule 8D, ruling that the assessee did not incur any actual expenditure to earn tax-free income of Rs. 14 crores. The court found that the assessee used its own interest-free funds for investments and did not rely on borrowed funds. The Tribunal correctly excluded dividend income from foreign subsidiaries, which is taxable, from disallowance. The 1% disallowance of interest expenditure was rejected as it was based on assumption rather than fact. The decision was rendered against Revenue. Case-Laws Income Tax Tue, 04 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248281