https://www.taxtmi.com/caselaws?id=456051 Section 40(a)(iib) was held inapplicable to guarantee commission paid by a State Government undertaking where the payment was contractual and not shown to be an exclusive statutory levy of the kind targeted by the provision; the disallowance was therefore unsustainable. For disallowance under section 14A read with rule 8D, only investments that actually yielded exempt dividend income during the year were to be included in the average value of investments; investments that produced no dividend income were to be excluded from the computation base. The assessee succeeded on both issues, and the Revenue's challenge failed. en-us Thu, 04 Mar 2021 00:00:00 +0530 Mon, 24 Jun 2024 20:51:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456051 Section 40(a)(iib) was held inapplicable to guarantee commission paid by a State Government undertaking where the payment was contractual and not shown to be an exclusive statutory levy of the kind targeted by the provision; the disallowance was therefore unsustainable. For disallowance under section 14A read with rule 8D, only investments that actually yielded exempt dividend income during the year were to be included in the average value of investments; investments that produced no dividend income were to be excluded from the computation base. The assessee succeeded on both issues, and the Revenue's challenge failed. Case-Laws Income Tax Thu, 04 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456051