2022 (6) TMI 115

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....ni ORDER Per R.S. Syal, VP This appeal by the assessee arises out of the order dated 08-08-2019 passed by the CIT(A)-11, Pune in relation to the assessment year 2013-14. 2. The only issue raised in this appeal is against the disallowance u/s. 14A of the Income-tax Act, 1961 (hereinafter also called 'the Act'). 3. Briefly stated, the facts of the case are that the assessee earned exemp....

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....o the issue pressed before the Tribunal, it is seen that the Hon'ble Delhi High Court in ACB India Ltd. vs. CIT (2015) 374 ITR 108 (Del) has held that the average value of investments, for the purposes of Rule 8D(2)(iii), should be confined to those securities in respect of which exempt income is earned and not the total investments. Similar view has been taken by the Special Bench of the Trib....