Strategic investment not part of average value of investment for disallowance u/r 8D(2)(iii) as no exempt income earned

DCIT Vs HCL Comnet Systems & Services Ltd (ITAT Delhi) ITAT Delhi held that strategic investments not yielding any exempt income during the year under consideration, the same cannot form part of the average value of investment for computing disallowance under rule 8D(2)(iii) of the Income Tax Rules. Facts- The assessee is a resident corporate entity and is stated to be engaged in the business of providing remote infrastructure management services and telecommunication services. In course of assessment proceedings, AO noticed that in the year under consideration, the assessee had earned exe...