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2023 (7) TMI 339 - ITAT AHMEDABADDisallowance u/s 14A - expenses incurred on earning exempt income - sufficiency of funds - Suo-moto disallowance made by assessee - HELD THAT:- No reason to deviate from the stand taken in assessee’s own case[2022 (12) TMI 447 - ITAT AHMEDABAD] in holding that since the assessee is having interest free funds much larger as compared to the investment, disallowance of assessee’s claim for interest expenditure by applying Section 14A of the Act was incorrect. As the assessee has already disallowed suo-moto in his return of income by making disallowance under Section 14A r.w. Rule 8D, the Ld. CIT(A) rightly deleted the amount on account of administrative expenditure made by the Ld. AO. The Ground of appeal filed by the Revenue is found to be devoid of merit and, thus, dismissed. Disallowance u/s 14A while computing income u/s 115 JB - HELD THAT:- As in assessee’s own case [2022 (12) TMI 447 - ITAT AHMEDABAD] relying upon the judgment passed by the Hon’ble Supreme Court in the case of Atria Power Corporation Ltd [2022 (8) TMI 1322 - SC ORDER] whereby held disallowance made under Section 14A of the Act could not be added in assessee company’s income for the purpose of computation of income u/s 115JB. Revenue appeal dismissed.
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