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2017 (7) TMI 1067 - AT - Income TaxDisallowance u/s 14A - Held that:- As the assessee earned exempt income of ₹ 1,70,000/- only during this Assessment Year and the Assessing Officer by invoking the provision of Section 14A made disallowance at ₹ 54,66,813/-. The Hon’ble Delhi High Court in the case of Joint Investment Private Limited [2015 (3) TMI 155 - DELHI HIGH COURT] held that by no stretch of imagination can section 14A or Rule 8D be interpreted so as to mean that entire tax exempt income is to be disallowed. In the case on hand since the assessee received dividend income of ₹ 1,70,000/- as recorded in the Assessment Order the disallowance should not be more than ₹ 1,70,000/-. Thus we direct the Assessing Officer to restrict the disallowance to the extent of dividend income i.e. ₹ 1,70,000/- and delete the balance amount and compute the incomes accordingly. - Decided in favour of assessee in part.
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