https://www.taxtmi.com/caselaws?id=407622 Section 14A read with Rule 8D(2)(iii) was held inapplicable where the amounts shown as investments in joint ventures were in substance accumulated profit and loss balances or current-account items, not actual investments capable of generating exempt income; the disallowance was deleted. The additional ground on restricting dividend distribution tax to the Article 10 treaty rate was admitted as a pure question of law, but factual verification of the treaty claim was still required, so the matter was remanded to the Assessing Officer for fresh examination with supporting evidence. en-us Wed, 21 Apr 2021 00:00:00 +0530 Fri, 05 Aug 2022 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407622 Section 14A read with Rule 8D(2)(iii) was held inapplicable where the amounts shown as investments in joint ventures were in substance accumulated profit and loss balances or current-account items, not actual investments capable of generating exempt income; the disallowance was deleted. The additional ground on restricting dividend distribution tax to the Article 10 treaty rate was admitted as a pure question of law, but factual verification of the treaty claim was still required, so the matter was remanded to the Assessing Officer for fresh examination with supporting evidence. Case-Laws Income Tax Wed, 21 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407622