CIT v. Hero Cycles Ltd.

323 ITR 518High Court2010#150 most cited

What is CIT v. Hero Cycles Ltd. authority for?

Disallowance under Section 14A, for expenditure incurred in relation to exempt income, is not permissible when the assessee has not earned any exempt income, such as dividend income under Section 10(34), during the year under consideration.

470

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Hero Cycles Ltd. · Section 14A disallowance · no exempt income earned · Section 10(34) dividend · expenditure nexus · disallowance if no dividend income · 323 ITR 518 · Hero Cycles 14A · exempt income disallowance

Also reported as

189 Taxmann 504 ITR-OL 246221 CTR 435

Sections most often in play

Section 14ASection 142(1)Section 143(3)Section 8DSection 143(2)Section 115JBSection 37(1)Section 43B
Read the full judgment

Issues it is cited on

section 10(34)disallowance under section 14adisallowance u/s 14asection 14asection 115jsection 115jbsection 37section 37(1)section 10section 115previous yearassistant commissioner

Judgments citing CIT v. Hero Cycles Ltd.

Gopalan Enterprises (P) Ltd vs. Addl C.I.T

In the result, the appeal of the revenue is partly allowed for statistical

ITA 158/BANG/2014[2010-11]Status: DisposedITAT Bangalore05 May 2017AY 2010-11

Bench: Shri A. K. Garodia & Shri Vijay Pal Rao

For Appellant: Shri K. R. Pradeep, C. AFor Respondent: Smt. Neera Malhotra, CIT DR
Section 14ASection 23

…. vs. DCIT (Supra). In this case also, the tribunal and learned CIT (A) had decided the issue by following the following three judgments:- a) CIT vs. Gujarat Industrial Development Corporation Ltd. as reported in 218 Taxman 142. b) CIT vs. Hero Cycles Ltd., 323 ITR 518 (P & H). c) CIT vs. Kribhco as reported in 349 ITR 618. 20. While dealing with the first tribunal order, we have already considered two judgments noted above at S. No. a) and c). The remaining one judgment is of Hon’ble P & H High Court rendered in the case of CIT vs. Hero Cycles Ltd. (Supra). In this case, the A. Y. involved is 2004 – 05 i.e.…

DCIT, Chennai vs. Neyveli Lignite Corporation Limited, Neyveli

In the result, the appeals of the Revenue as well as the appeal of the assessee are partly allowed

ITA 855/CHNY/2013[2009-2010]Status: DisposedITAT Chennai28 Apr 2017AY 2009-2010

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

…d opinion that there was no objective reason for non-satisfaction of the AO to invoke rule 8D. On similar facts, additions made in AYs 2006-07 and 2007-08 were deleted by CIT(A). The decisions relied on by the appellant in the cases of CIT v. Hero Cycles Ltd, 323 ITR 518 (P&H) and CIT v. Reliance Utilities and Power Ltd, 221 CTR 435(Bom) also supports the case of the appellant. In view of the above factual and legal positions, the addition is deleted and the ground is allowed. 6.3 Both the Ld.AR and the Ld.DR brought to our notice that on the same facts in the assessee’s own case in ITA Nos.712 & 713/2010 dated…

Neyveli Lignite Corporation Ltd., Cuddalore vs. DCIT, Chennai

In the result, the appeals of the Revenue as well as the appeal of the assessee are partly allowed

ITA 2140/CHNY/2013[2010-11]Status: DisposedITAT Chennai28 Apr 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

…d opinion that there was no objective reason for non-satisfaction of the AO to invoke rule 8D. On similar facts, additions made in AYs 2006-07 and 2007-08 were deleted by CIT(A). The decisions relied on by the appellant in the cases of CIT v. Hero Cycles Ltd, 323 ITR 518 (P&H) and CIT v. Reliance Utilities and Power Ltd, 221 CTR 435(Bom) also supports the case of the appellant. In view of the above factual and legal positions, the addition is deleted and the ground is allowed. 6.3 Both the Ld.AR and the Ld.DR brought to our notice that on the same facts in the assessee’s own case in ITA Nos.712 & 713/2010 dated…

DCIT, Chennai vs. M/S. Neyveli Lignite Corporation Limited, Neyveli

In the result, the appeals of the Revenue as well as the appeal of the assessee are partly allowed

ITA 2077/CHNY/2013[2010-11]Status: DisposedITAT Chennai28 Apr 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

…d opinion that there was no objective reason for non-satisfaction of the AO to invoke rule 8D. On similar facts, additions made in AYs 2006-07 and 2007-08 were deleted by CIT(A). The decisions relied on by the appellant in the cases of CIT v. Hero Cycles Ltd, 323 ITR 518 (P&H) and CIT v. Reliance Utilities and Power Ltd, 221 CTR 435(Bom) also supports the case of the appellant. In view of the above factual and legal positions, the addition is deleted and the ground is allowed. 6.3 Both the Ld.AR and the Ld.DR brought to our notice that on the same facts in the assessee’s own case in ITA Nos.712 & 713/2010 dated…

DCIT, Chennai vs. M/S. Neyveli Lignite Corporation Limited, Neyveli

In the result, the appeals of the Revenue as well as the appeal of the assessee are partly allowed

ITA 2029/CHNY/2013[2007-08]Status: DisposedITAT Chennai28 Apr 2017AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

…d opinion that there was no objective reason for non-satisfaction of the AO to invoke rule 8D. On similar facts, additions made in AYs 2006-07 and 2007-08 were deleted by CIT(A). The decisions relied on by the appellant in the cases of CIT v. Hero Cycles Ltd, 323 ITR 518 (P&H) and CIT v. Reliance Utilities and Power Ltd, 221 CTR 435(Bom) also supports the case of the appellant. In view of the above factual and legal positions, the addition is deleted and the ground is allowed. 6.3 Both the Ld.AR and the Ld.DR brought to our notice that on the same facts in the assessee’s own case in ITA Nos.712 & 713/2010 dated…

DCIT, Chennai vs. M/S. Neyveli Lignite Corporation Limited, Neyveli

In the result, the appeals of the Revenue as well as the appeal of the assessee are partly allowed

ITA 1983/CHNY/2011[2008-09]Status: DisposedITAT Chennai28 Apr 2017AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

…d opinion that there was no objective reason for non-satisfaction of the AO to invoke rule 8D. On similar facts, additions made in AYs 2006-07 and 2007-08 were deleted by CIT(A). The decisions relied on by the appellant in the cases of CIT v. Hero Cycles Ltd, 323 ITR 518 (P&H) and CIT v. Reliance Utilities and Power Ltd, 221 CTR 435(Bom) also supports the case of the appellant. In view of the above factual and legal positions, the addition is deleted and the ground is allowed. 6.3 Both the Ld.AR and the Ld.DR brought to our notice that on the same facts in the assessee’s own case in ITA Nos.712 & 713/2010 dated…

Hcc Real Estate Ltd, Mumbai vs. DCIT 10(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2209/MUM/2015[2010-11]Status: DisposedITAT Mumbai21 Apr 2017AY 2010-11

Bench: Shri G.S. Pannu & Shri Ram Lal Negi: (A.Y : 2010-11)

For Appellant: Shri Vikrant Rajopadhye/For Respondent: Ms. Aarju Garodia
Section 143(3)Section 14A

…to satisfy the pre-condition that expenditure has been incurred to earn such exempt income and in this context relied on the following judgments :- i) CIT vs Consolidated Photo & Finvest Ltd [2012] 211 Taxman 184 (Del); and ii) CIT vs Hero Cycles Ltd [2010] 323 ITR 518 (P&H). 8 M/s. HCC Real Estate Ltd. 11. On the other hand, the ld. DR defended the orders of the authorities below by placing reliance on the same. 12. We have carefully considered the rival submissions. Notably, in the present case, the Assessing Officer has computed the disallowance u/s 14A of the Act by applying formula contained Rule 8D of…

Kotak Mahindra Bank Ltd, Mumbai vs. Addl CIT RG 3(2), Mumbai

The appeals of the AO are dismissed

ITA 1929/MUM/2012[2008-09]Status: DisposedITAT Mumbai18 Apr 2017AY 2008-09
For Appellant: F.V. IraniFor Respondent: R P Meena
Section 143(3)Section 254(1)Section 36

…IT v. Cocanada Radhaswami Bank Ltd. [1965] 57 ITR 306 (SC) (para 14) iv. CIT v. Corrtech Energy (P.) Ltd. [2015] 372 ITR 97 (Guj) (para 15) v. CIT v.Holcim India (P.) Ltd.(I.T.A.No.486 of 2014 decided on 5- 9-2014) (para 15) vi. CIT v. Hero Cycles Ltd. [2010] 323 ITR 518 (P&H) (para 15) vii. CIT v. Lakhani Marketing Incl. [2015] 4 ITR-OL 246 (P&H) (para 15) viii. CIT v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC) (para 10) ix.CIT v.Shivam Motors (P.) Ltd. (ITA No. 88 of 2014 decided on 5-5-2014) (para 15) x. IT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204 (P&H) (para 15) , xi. Eicher Goodearth Ltd. vs.…

Vijay Industries, Alwar vs. ACIT, Alwar

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 778/JPR/2016[2012-13]Status: DisposedITAT Jaipur17 Mar 2017AY 2012-13

Bench: The Hon’Ble

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri R.C.Verma (Addl. CIT)
Section 14Section 14A

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 778/JP/2016 fu/kZkj.k o"kZ@Assessment Year :2012-2013 cuke ACIT, Circle-1 Alwar M/s Vijay Industries, Vs. Cinema Road, Khairthal (Alwar)- 301404 LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAAFV 7282R vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri P.C. Parwal (C.A.) jktLo dh vksj ls@ Revenue by : Shri R.C.Verma (Addl. CIT) lquokbZ…

Smt. Abhadevi Narendra Agrawal, Burhanpur vs. The ACIT, Khandwa

In the result, appeal of the assessee stands partly allowed

ITA 58/IND/2015[2010-11]Status: DisposedITAT Indore16 Mar 2017AY 2010-11

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./ I.T.A. No.58/Ind/2015 "नधा"रणवष" /Assessment Year: 2010-11

Section 14ASection 41(1)

…interest free funds were given out of interest free funds available at the disposal of the assessee as per balance sheet of the assessee. We further rely on the decision of Hon`ble Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd. (2010) 323 ITR 518(P&H) wherein it was held that no disallowance out of Smt. Abhadevi Agarwal/ I.T.A. No.58/Ind/2015/A.Y.:10-11 Page 8 of 19 interest payment is permissible if AO does not establish nexus between the expenditure incurred and income generated. Therefore, by applying the ratio as laid down by the Hon’ble Bombay High Court in in the case of CIT vs.…

D.C.I.T., Circle-4, Kolkata vs. M/S. Rossell India Ltd., Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 2774/KOL/2013[2009-2010]Status: DisposedITAT Kolkata15 Mar 2017AY 2009-2010

Bench: Shri Aby.T Varkey & Shri Waseem Ahmedassessment Year:2009-10 Dcit, Circle-4, Kolkata V/S. M/S Rossell India Ltd. P-7, Chowringhee 21/1A/3, Darga Road, Square, Kolkata-69 Jindal Towers, Block B, 4Th Floor, Park Circus, Kolkta-700 017 [Pan Noaabcr 3736 J] .. अपीलाथ" /Appellant ""यथ"/Respondent

Section 10(34)Section 115JSection 143(3)Section 14A

…re & Stock Brokers P Ltd. (2010) 326 ITR 1 (SC) CIT vs. Ashish Jhunjhunwala [GA No.2990 of 2013](Cal) DCIT vs. Allahabad Bank [ITA No.1282 of 2012 dated 01.06.2016 (Kol) ACIT vs. Pawan Kumar Jhunjhunwala (2016) 157 ITD 667 (Kol) CIT vs. Hero Cycles Ltd (2010) 323 ITR 518 (P&H) Godrej and Boyee Mfg. Co. Ltd. vs. DCIT (2010) 328 ITR 81 (Bom) As per Sec. 14A(2), provisions of Rule 8D comes into play only when the AO records a finding that he is not satisfied with the respondent’s method. The AO has failed to record any finding/reasons as to why he was not satisfied with respondent’s method. Hence, recourse to Rule…

M/S. Chhaganlal Kishanlal & Co., Burhanpur vs. The ACIT, Khandwa

In the result, the appeal of the assessee stands allowed

ITA 646/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M. Garg & Shri O.P. Meena

…interest free funds were given out of interest free funds available at the disposal of the assessee as per balance sheet of the assessee. We further rely on the decision of Hon`ble Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd. (2010) 323 ITR 518(P&H) wherein it was held that no disallowance out of interest payment is permissible if AO does not establish nexus between the expenditure incurred and income generated. Therefore, by applying the ratio as laid down by the Hon’ble Bombay High Court in in the case of CIT vs. Reliance Utilities & Power Ltd. (2009) 178 Taxman 135 (Bom) and the de…

M/S. Rahul Developers Pvt. Ltd., Burhanpur vs. The ACIT, Khandwa

In the result, the appeal of the assessee stands allowed

ITA 645/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M.Garg & Shri O.P. Meena

…interest free funds were given out of interest free funds available at the disposal of the assessee as per balance sheet of the assessee. We further rely on the decision of Hon`ble Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd. (2010) 323 ITR 518(P&H) wherein it was held that no disallowance out of interest payment is permissible if AO does not establish nexus between the expenditure incurred and income generated. Therefore, by applying the ratio as laid down by the Hon’ble Bombay High Court in in the case of CIT vs. Reliance Utilities & Power Ltd. (2009) 178 Taxman 135 (Bom) and the de…

M/S. Narendra Industries, Burhanpur vs. The ACIT, Khandwa

In the result, the appeal of the assessee stands partly allowed

ITA 644/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M.Garg & Shri O.P. Meena

…M/s. Narenda Industries vs ACIT,Khandwa I.T.A.No. 644/Ind/2015 Page 1 of 10 आयकर अपील"य अ"धकरण ,इ"दौर "यायपीठ ,इ"दौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE "ी सी. एम. गग", "या"यक सद"य तथा "ी ओ.पी.मीना ,लेखा सद"य के सम" BEFORE SHRI C.M.GARG, JUDICIAL MEMBER AND SHRI O.P. MEENA, ACCOUNTANT MEMBER आ.अ.सं /.I.T.A. No.644/Ind/2015 "नधा"रण वष" / Assessment Year:2010-11 M/s. Narendra vs. ACIT Khandwa Industries, Bahadarpur Road, Burhanpur अपीलाथ" / अपीलाथ" /Appellant अपीलाथ" / अपीलाथ" / ""यथ" / ""यथ" /Respondent ""यथ" / ""यथ" / "था.ले.सं./PAN: AAAFN7193D अपीलाथ" क" ओर से/ अपीलाथ" क" ओर से/Appellant…

M/S. C.K. Cotspin Pvt. Ltd., Burhanpur vs. The DCIT, Khandwa

In the result, the appeal of the assessee is allowed

ITA 816/IND/2014[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri C.M. Garg & Shri O.P. Meena

…T.A. No.816/Ind/2014/A.Y.:11-12 Page 12 of 23 funds for the commercial expediency then no disallowance could be made under section 36 (1) (iii) of the Act. 1.3.7. The Ld. A.R. further placed reliance on following judgement : CIT vs. Hero Cycles Ltd. (2010) 323 ITR 518 (P&H) wherein it was held that no disallowance out of interest payment is permissible if AO does not establish nexus between the expenditure incurred and income generated. The Ld. A.R. submitted that in the present case the AO has failed to establish that the assessee had diverted interest bearing funds for non business purposes or advanced…

Priya Ltd., Mumbai vs. DCIT (OSD), Cir 2(3), Mumbai

The appeal of the assessee is disposed off in terms indicated hereinabove and the appeal of the Revenue is dismissed

ITA 3231/MUM/2015[2010-11]Status: DisposedITAT Mumbai21 Feb 2017AY 2010-11

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2010-11 Priya Ltd. Dcit(Osd), Circle-2(3), 209-210, Kimatraj Building बनाम/ R. No. 552, 5Th Floor, 02 Floor, 77/79 Vs. Aayakar Bhavan, M.K.Road, M.K. Road, Mumbai-400020 Mumbai-400002 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacp2210Q Assessment Year: 2010-11 Dcit(Osd), Priya Ltd. 209-210, Kimatraj Building Circle-2(3), बनाम/ 02 Floor, 77/79 R. No. 552, 5Th Floor, Vs. M.K. Road, Aayakar Bhavan, M.K.Road, Mumbai-400002 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacp2210Q

Section 10(33)Section 143(3)Section 14ASection 260A

…ssioner of Income Tax, Faridabad v. M/s. Lakhani Marketing Incl. (decision dated 2nd April 2014 of the High Court of Punjab and Haryana in ITA No. 970/2008) which in turn referred to two earlier decisions of the same Court in CIT v. Hero Cycles Limited [2010] 323 ITR 518 and CIT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204. The second was of the Gujarat High Court in Commissioner of Income Tax-I v. Corrtech Energy (P) Ltd. [2014] 223 Taxmann 130 (Guj.) and the third of the Allahabad High Court in Commissioner of Income Tax, Kanpur v. Shivam Motors (P) Ltd. (decision dated 5th May 2014 in ITA No. 88/2014)…

Lakhani Shoee Co. Pvt. Ltd vs. ACIT, Alwar

In the result, appeal of the assessee in ITA No

ITA 854/JPR/2016[2012-13]Status: DisposedITAT Jaipur20 Feb 2017AY 2012-13
For Appellant: Shri S.C. Vasudeva (C.A)For Respondent: Shri S.L. Chandel (Addl.CIT)
Section 143(3)Section 14A

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 854/JP/2016 fu/kZkj.k o"kZ@Assessment Year : 2012-13. cuke M/s Lakhani Shoe Co. Pvt. Ltd. Asst. Commissioner of Income Tax, Vs. Plot No. 130, Sector-24, Circle-2, Faridabad – 121005 Alwar. LFkk;h ys[kk la-@thvkbZvkj la-@PAN No. AAACL 2991 A vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri S.C. Vasudeva (C.A) jktLo dh vksj ls@ Revenu…

Kamanwala Housing Construction Ltd, Mumbai vs. Addl CIT 6(2), Mumbai

In the result, this appeal is partly allowed

ITA 921/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Feb 2017AY 2011-12

Bench: Shri Mahavir Singh & Shri Ashwani Tanejaassessment Year: 2011-12

Section 143(3)Section 234BSection 27Section 40A(2)(b)Section 5

…ombay High Court. 3. CIT v. Corrtech Energy (P.) Ltd. 45 taxmann.com 116 (Gujarat) 4. CIT v. Shivam Motors- Judgment dated 5.5.2014 of All High Court 5. CIT v. Lakhani Marketing Incl. Judgment dated 02.04.2014 (P & H) 6. CIT v. Winsome Textile Industries Ltd. 319 ITR 203(P & H) 7. M/s. Daga Global Chemicals Pvt. Ltd. v. ACIT ITA No.5592/Mum/2012 8. ITO v. Pioneer Radio Training Services Pvt. Ltd. ITA No.4448/Del/2013 11.3. Per contra Ld. DR relied upon the order of the AO. 11.4. We have gone through the facts and circumstances of the case. It is admitted case that no exempt income has been earned during the year,…

DCIT Cir 6(3)(2), Mumbai vs. Kamanwala Housing Construction Ltd, Mumbai

In the result, this appeal is partly allowed

ITA 1404/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Feb 2017AY 2011-12

Bench: Shri Mahavir Singh & Shri Ashwani Tanejaassessment Year: 2011-12

Section 143(3)Section 234BSection 27Section 40A(2)(b)Section 5

…ombay High Court. 3. CIT v. Corrtech Energy (P.) Ltd. 45 taxmann.com 116 (Gujarat) 4. CIT v. Shivam Motors- Judgment dated 5.5.2014 of All High Court 5. CIT v. Lakhani Marketing Incl. Judgment dated 02.04.2014 (P & H) 6. CIT v. Winsome Textile Industries Ltd. 319 ITR 203(P & H) 7. M/s. Daga Global Chemicals Pvt. Ltd. v. ACIT ITA No.5592/Mum/2012 8. ITO v. Pioneer Radio Training Services Pvt. Ltd. ITA No.4448/Del/2013 11.3. Per contra Ld. DR relied upon the order of the AO. 11.4. We have gone through the facts and circumstances of the case. It is admitted case that no exempt income has been earned during the year,…

Lebong Investments Pvt. Ltd., Kolkata vs. D.C.I.T., Circle-11, Kolkata

In the result, assessee’s appeal stands allowed

ITA 2652/KOL/2013[2009-2010]Status: DisposedITAT Kolkata18 Jan 2017AY 2009-2010

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2009-10

Section 143(3)Section 14A

…rmining such expenditure has been introduced by virtue of sub- section (2) of section 14A. Prior to that, the assessing was free to adopt any reasonable and acceptable method. 14. The Hon'ble Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd 323 ITR 518 (P&H) has also held that disallowance under section 14A could not stand where it was found that for earning exempted income no expenditure has been incurred: “Held - dismissing the appeal, that the expenditure on interest was set off against the income from interest and the investment in the shares and funds were out of the dividend proceeds. In…