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2014 (2) TMI 70 - ITAT MUMBAIDisallowance made u/s 14A of the Act r.w. Rule 8D of the Rules – Whether payment of interest to broking companies and NBFC excludable or not – Held that:- THe CIT(A) has rendered a well-considered and well discussed decision after considering each and every aspect of the matter involved in the disallowance to be made u/s 14A of the Act by applying Rule 8-D - He has identified the common expenses which were partly attributable to the earning of exempt dividend income and accordingly has quantified the disallowance to be made out of the said expenses on proportionate basis - He has also directed the A.O. to verify the stand of the assessee of having incurred the interest expenses in relation to the activity of trading in shares and to apply the formula given in Rule 8-D for the purpose of making disallowance out of interest on such verification - He has also rightly rejected the contention of the assessee that the average value of investment in its books is nil after having found the same to be in-correct – Relying upon Income-tax Officer, Ward 6(2) (2), Mumbai Versus Daga Capital Management (P.) Ltd. [2008 (10) TMI 383 - ITAT MUMBAI ] - the decision rendered by the CIT(A) on the issue is well founded and the revenue has not been able to raise any material contention to dispute this position – order of the CIT(A)0 upheld – Decided against Revenue.
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