https://www.taxtmi.com/caselaws?id=311457 For a bank, dividend earned from shares held as stock-in-trade did not justify disallowance under section 14A read with rule 8D in the same manner as investment income, because the dividend was incidental and the apportionment theory was inapplicable on those facts; the disallowance under rule 8D(2)(iii) was deleted. The claim to exclude profits of overseas branches under the applicable treaty framework was rejected as covered against the assessee by the coordinate bench decision in its own case. Where the bank had sufficient own interest-free funds to cover the investments, the presumption that investments came from those funds applied, and deletion of the interest disallowance under rule 8D(2)(ii) was upheld. en-us Wed, 28 Jun 2023 00:00:00 +0530 Wed, 27 Dec 2023 09:01:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311457 For a bank, dividend earned from shares held as stock-in-trade did not justify disallowance under section 14A read with rule 8D in the same manner as investment income, because the dividend was incidental and the apportionment theory was inapplicable on those facts; the disallowance under rule 8D(2)(iii) was deleted. The claim to exclude profits of overseas branches under the applicable treaty framework was rejected as covered against the assessee by the coordinate bench decision in its own case. Where the bank had sufficient own interest-free funds to cover the investments, the presumption that investments came from those funds applied, and deletion of the interest disallowance under rule 8D(2)(ii) was upheld. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311457