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2019 (11) TMI 585 - ITAT MUMBAIDisallowance u/s 14A - suo-mto disallowance made by the appellant - HELD THAT:- It is clear that the AO despite the fact that all the books of accounts were produced before him, he could not point out any nexus with the exempt income and that of the expenditure relatable to this exempt income. Even the Hon’ble Supreme Court in the case of Godrej & Boyce Mfg. Co. Ltd. [2017 (5) TMI 403 - SUPREME COURT] has clearly laid down the principle that the satisfaction of the AO must be there for making disallowance under section 14A of the Act read with Rule 8D of the Rules. In the present case, the satisfaction is missing in all the years. MAT Computation - disallowances made while determining the income under section 115JB - HELD THAT:- It is settled law that disallowance made under section 14A r.w.r. 8D cannot be applied while determining the book profit under section 115JB of the Act, in this regard we place our reliance on the order of Hon’ble Jurisdictional High Court in the matter of CIT vs, M/s. Bengal Finance & Investments Pvt. Ltd [2015 (2) TMI 1263 - BOMBAY HIGH COURT]
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