Section 14A disallowance- Consider only those Investment which yielded exempt income

ITO Vs Manoj Vashudev Wadhwa (ITAT Mumbai) In ACIT v. Vireet Investment (P.) Ltd. 165 ITD 27 (Del) (SB) it is held by the Special Bench of the Tribunal that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. We are of the considered view that the ratio laid down in the above decision is squarely applicable in the instant case. Therefore, we set aside the order of the Ld. CIT(A) for the impugned assessment years and restore the matter to the file of the AO to make a de novo order after following the ratio laid down ...