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2013 (9) TMI 1062 - AT - Income TaxDisallowance u/s.14A applying Rule 8D - Held that:- There cannot be profit on the transfer of the mutual funds but as we have held that there is no specific finding by the AO nor by the CIT(A) that infact the assessee has used the interest bearing funds for investment, on this factual aspect, we hold that there is no justification to make the disallowance. We accordingly delete the addition made by the AO u/s.14A r.w. Rule 8D as the mandate of section 14A(1) is not fulfilled. - Decided in favour of assessee
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