2022 (1) TMI 333

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....ssessee company is a subsidiary of Punjab National Bank with the object of creating a market for government securities. Under a license from RBI, the assessee has been acting as a primary dealer in Government securities. Assessee is a trader in the government securities markets including treasury Bills and other debt instruments like PSU Bonds, interest Rate Derivatives and other money market instruments and is registered as an NBFC with RBI. 3. For the assessment year 2014-15, the assessee filed their return of income on 25.09.2014 declaring an income of Rs. 85,62,26,770/-. Assessment u/s. 143(3) of the Income-tax Act, 1961 (for short "the Act") was complete by order dated 30.12.2016 by making an addition of Rs. 2,19,41,880/- u/s. 14A of ....

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....dition of Rs. 2,19,41,880/- made by the Assessing Officer, Revenue preferred this appeal. 6. Learned DR places heavy reliance on the assessment order and submitted that the assessee had received exempt income of Rs. 4,58,21,781/- and therefore, ld. CIT(A) is not justified in restricting the disallowance to Rs. 21,94,188/-, deleting the addition of Rs. 1,97,74,692/-. 7. Learned AR reiterated before us the same submissions made before the ld. CIT(A) and stated that for the purpose of computing the disallowance u/r 8D(2)(iii), only such investments which yield dividend has to be considered but not the entire investment in view of the decision of jurisdictional High Court in the case of ACIT vs. Acb India Ltd. (supra) and therefore, the order....