TaxTMI 
TaxTMI 
2017 (2) TMI 285
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....IT(A) for the assessment year 2011-12. 2. The only grievance of assessee relates to disallowance of expenses by invoking provisions of Section14A read with Rule 8D(2)(iii) amounting to Rs. 12,48,394/-. 3. It was argued by learned AR that while computing disallowance under Rule 8D(2)(iii), AO has taken into account the shares held as stock in trade, strategic investment and investment in immovabl....
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.... that the assessee is a broker at the BSE and the NSE and is engaged in the business of share broking, investing and trading in shares and securities, mutual fund distribution, arbitrage activity on equity and derivative segment, providing financial consultancy services. While computing disallowance u/s.14A, AO has taken into account the shares which were held as stock in trade and on which no div....
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....s made the disallowance u/s 14A r.w. Rule 8-D at 0.5% of administrative expenses. There was no disallowance on account of interest while working out the disallowance u/s 14A of the Income Tax Act, 1961. It was argued by the learned A.R. that the assessee has investments in companies which are its group companies where the assessee holds substantial stake. The Id. A.R. submits that strategic invest....
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....A 605 of 2012(HC) viii) ACIT vs. Oriental Structural Engineers P. Ltd. ITA No. 4245/De1/2011 ix) Garware Wall Ropes Ltd. vs. ACIT - ITA No. 5408/M/2012 7. In view of the above judicial pronouncements, I direct the A.O. to exclude the investments made in foreign subsidiaries and investment made in companies which are strategic in nature while computing the disallowance u/s 14A of the Act in ....