Dispute Over Tax Disallowance: Should Only Tax-Exempt Investments Be Included in Section 14A Calculations?

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....Disallowance u/s 14A r.w.r. 8D - as argued CIT(A), instead of adopting the average value of investment of which income is not part of the total income i.e., the value of tax- exempt investment, chose to factor in the total investment itself - while calculating disallowance under section 14A of the Act, only investment that have generated exempt income should be taken into consideration. - AT....