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2014 (1) TMI 1579 - AT - Income TaxDisallowance u/s 14A - Held that:- The assessee had sufficient interest free funds which it had invested in mutual funds and moreover the assessee instead of incurring expenditure in the form of interest has earned income - Ld CIT(A) has rightly deleted the interest component from the disallowance of Rule 8D - Decided against Revenue. Whether adjustment of disallowance u/s 14A be deleted while computing book profits u/s 14A - Held that:-The provisions of clause (g) to section 115JB refers to the amount of expenditure incurred for earning exempt income which has to be added back to the profit as per P&L A/c for the purpose of calculation of book profits u/s 115JB - The assessee has not incurred any expenditure in earning exempt income - Disallowance u/s 14A has been deleted by the CIT(A) - Decided against Revenue. Whether income derived from operations & maintenance of SEZ be deleted from book profits when the same has not been claimed by the assessee - Held that:- As per clause (6) of section 115JB - The provision of this section shall not apply to the income accrued or arising on or after the Ist day of April, 2005 from any business carried on or services rendered by an entrepreneur or a developer in a unit or SEZ - The assessee was eligible for exclusion of income from SEZ business for the purpose of section 115JB - The claim of assessee with respect to SEZ income has not been examined by the Assessing Officer or by ld CIT(A) - The issue has been restored for fresh adjudication.
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