Section 14A of the Income Tax Act, 1961 — Expenditure incurred in relation to income not included in total income — It is the only investments which yielded dividend during the previous year that has to be considered while adopting the average value of investments for the purpose of rule 8D (2)(ii) and (iii) of the IT rules, 1962. Borrowed funds were not used for making investments in shares, therefore, a presumption was drawn that all the investments had been made out of assessee's own funds and no part of the interest paid on loan funds could be directly or indirectly attributed to the investments from which exempt income had been earned, thus, disallowance was deleted — Peerless General Finance And Investment Co. Ltd. vs. Deputy Commissioner of income tax [2019] 76 ITR (trib) 356 (Kolkata)