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The ground raised by the assessee is with regard to disallowance made u/s.14A of the Act r.w.Rule 8D(2) of the Rules.

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Sec. 14A of Income Tax Act, 1961—Disallowance— Assessee being a bank, investments held as ‘stock in trade’ should not be considered for the purpose of working of disallowance u/s.14A irrespective of the fact whether exempt income was derived from such investments or not - Strategic investments held by the assessee which had yielded exempt income alone are to be considered for the purpose of working out the disallowance u/s.14A read with Rule 8D(2)(iii). - HDFC BANK LTD. V/s ASSTT. CIT - [2020] 82 ITR (TRIB) 533 (ITAT-MUMBAI)