Case Law Details
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, prior to its amendment w.e.f. 02.06.2016, amount of expenditure by way of interest would be the interest paid by the assessee on borrowings minus taxable interest earned during the financial year.
FULL TEXT OF THE ITAT JUDGEMENT
This is an appeal filed by the assessee against the order dated 20.10.2015 passed by the learned Commissioner of Income Tax (Appeals)-3, Delhi ( Ld. CIT(A)) for A.Y. 2011-12.
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