Whether ratio of expenditure disallowance in lieu of interest payments u/s 14A has to be in the ratio of dividend income to total turnover?

Once it is not in dispute that the facts of the case are materially similar to the facts of ISG Traders Ltd. vs. CIT, WB-II, Kolkata (I.T,A No.264 of 2003-2011- TIOL-621-HC-KOL-IT). And that the said decision applies in this case, the computation of disallowance has to be done on the same basis as was accepted by Their Lordships in ISG Traders Ltd.’s case (supra). As learned counsel rightly points out, the ratio of allocation accepted by Their Lordships is of dividend income to total turnover. In view of this position, we deem it fit and proper to uphold the grievance of the assessee and to ...