Consider Net Interest expenses for section 14A disallowance: ITAT Delhi

DCIT Vs M/s. DLF Assets Pvt. Ltd. (ITAT Delhi) On the aspect of disallowance made by the Ld. AO by invoking the provisions u/s 14A of the Act r/w Rule 8D (2) (ii) of the Rules, it is the submission of the Ld. AR that the interest expenses net of interest income may be considered for working of disallowance. Ld. DR relied upon the assessment order. The decision of Hon’ble High Court in PCIT Vs. Nirma Credit & Capital (P) Ltd. is brought to our notice and it is so held in the said decision that for the purpose of applying factors contended in clause (ii) of sub-rule (2) of rule 8D, pri...