Section 14A disallowance for stock in trade clarified; refund interest under Section 244A must be applied before adjustments.
The Tribunal held that where investments are held as stock in trade by a bank, disallowance under Section 14A is not appropriate because such holdings are business related trading assets rather than investments to earn exempt dividends; additionally, for Section 244A interest on refunds, interest payable to the assessee must be computed and applied before making adjustments against tax, so earlier refund interest should not be deducted when calculating refund interest due.