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2015 (7) TMI 1344 - ITAT CHANDIGARHAddition u/s. 14A r.w. rule 8D (subject to relief on investment in debentures) - whether no satisfaction had been recorded by Assessing Officer for making the disallowance in respect of the submissions made before him - whether no expenditure had been incurred by the appellant to earn the exempt income and also the Assessing Officer has not pointed out any expenditure having been incurred by the appellant? - HELD THAT:- New investments have definitively been made in various mutual funds and some of the funds are designated as dividend plans which itself means that assessee is going to earn dividend which is exempt from tax. Further, wherever no dividend is received from the market fund the sale of funds also may be exempted in the case of long term funds. In some cases there may not be any exempted income. This aspect was examined by Ld. CIT(A) and he has remitted the matter back to the file of Assessing Officer for examination of the issue whether disallowance under Rule 8D(2)(iii) is properly computed with respect to the contention that on certain investments no exempt income would arise. Once the above aspect has been remanded, we find nothing wrong with the order of Ld. CIT(A). At best, the Assessing Officer can also point out how he is not satisfied with the correctness of the accounts with reference to the disallowance of ₹ 50,000/- made by the assessee in respect of section 14A of the Act. Resultantly the appeal stands dismissed.
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