Section 14A applicable to strategic investment generating exempt dividend income

ACIT Vs Assam Bengal Carriers (ITAT Kolkata) Introduction: The case of ACIT vs. Assam Bengal Carriers, adjudicated by ITAT Kolkata, delves into the intricacies of Section 14A disallowance. The backdrop includes the Supreme Court’s significant ruling in Maxopp Investment Ltd. vs CIT, emphasizing the necessity of apportioning expenditure concerning dividend income. Detailed Analysis: The Assessing Officer (A.O.) disallowed ₹1,36,02,161 under Section 14A, applying Rule 8D, rejecting the assessee’s claim that strategic investments incurred nominal or no expenditure. The A.O. believed...