Dxc Technology India Pvt Ltd,Indore vs Deputy Commissioner Of Income Tax, ... on 8 May, 2025
having any rationality in the facts of case. For this, he submitted that the
assessee has earned tax-free dividend from 'debt mutual funds' which are
passive investments for which no day-to-day monitoring or administration
was required, at the most only services of employees of treasury function
was required whose salary had already been disallowed by assessee. Thus,
no further disallowance is warranted in case of 'debt mutual funds'. Ld. AR
relied upon a decision of ITAT, Delhi in M/s Gujarat Guardian Ltd. Vs.
DCIT, Circle 10(2), New Delhi - ITA No. 5794/Del/2016 which is a case
dealing with 'debt mutual funds' and holding such a proposition. Then, Ld.
AR also drew us to the audited financial statements of assessee filed in
Paper-Book in an attempt to show that (i) the assessee is mainly engaged in
software development business and the revenue derived from software
business was Rs. 2710.33 crore whereas the tax-free dividend was just Rs.
33.93 crore, and (ii) that the various expenses debited to P&L A/c cannot be
said to have been incurred for earning impugned tax-free dividend from
'debt mutual funds', and (iii) that the assessee has not utilized any borrowed
fund for making investments from which impugned dividend was earned.