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    <title>2022 (6) TMI 1560 - ITAT DELHI</title>
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    <description>Disallowance under section 14A read with Rule 8D was restricted where the assessee&#039;s own non-interest-bearing funds exceeded the exempt-income investments, supporting the presumption that such investments were made from interest-free funds. On those facts, the interest component under Rule 8D was not justified because borrowed funds were deployed in the lending business. For the administrative expense component, only investments that actually yielded exempt income could be included in the Rule 8D base, not the full investment portfolio. The appellate recomputation on that basis was upheld.</description>
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      <title>2022 (6) TMI 1560 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=468382</link>
      <description>Disallowance under section 14A read with Rule 8D was restricted where the assessee&#039;s own non-interest-bearing funds exceeded the exempt-income investments, supporting the presumption that such investments were made from interest-free funds. On those facts, the interest component under Rule 8D was not justified because borrowed funds were deployed in the lending business. For the administrative expense component, only investments that actually yielded exempt income could be included in the Rule 8D base, not the full investment portfolio. The appellate recomputation on that basis was upheld.</description>
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      <pubDate>Mon, 27 Jun 2022 00:00:00 +0530</pubDate>
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