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    <title>2018 (6) TMI 603 - ITAT DELHI</title>
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    <description>Investments in OMIFCO, Oman were excluded from the Rule 8D(2)(iii) disallowance under Section 14A because the dividend income was already treated as part of total income only through relief under Section 90(2) read with the Indo-Oman DTAA. The same approach had been followed in earlier years, where the OMIFCO investment was directed to be excluded when recomputing the disallowance. On that basis, the investment was not treated as generating income justifying inclusion for Section 14A purposes, and the exclusion was upheld in favour of the assessee.</description>
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      <title>2018 (6) TMI 603 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=361776</link>
      <description>Investments in OMIFCO, Oman were excluded from the Rule 8D(2)(iii) disallowance under Section 14A because the dividend income was already treated as part of total income only through relief under Section 90(2) read with the Indo-Oman DTAA. The same approach had been followed in earlier years, where the OMIFCO investment was directed to be excluded when recomputing the disallowance. On that basis, the investment was not treated as generating income justifying inclusion for Section 14A purposes, and the exclusion was upheld in favour of the assessee.</description>
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      <pubDate>Thu, 07 Jun 2018 00:00:00 +0530</pubDate>
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