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2014 (3) TMI 928 - ITAT CHENNAIDeleting of dis-allowance u/s.14A of the Act r.w. Rule 8D – Held that:- The decision in Godrej & Boyce Mfg. Co. Ltd v. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] followed - Rule 8D is applicable from assessment year 2008-09 – it cannot now turn around and say that no expenditure whatsoever was incurred for earning the exempt income – thus, the matter is remitted back to the AO for fresh adjudication – Decided in favour of Revenue. Deletion of dis-allowance u/s 40a(i) of the Act - Overseas payments of professional and consultancy charges – TDS not deducted - The decision in CIT Vs. M/s. Vector Shipping Services (P) Ltd. [2013 (7) TMI 622 - ALLAHABAD HIGH COURT] followed - the provisions of section 40a(i) do not apply to those amounts which have already been paid by the assessee before the close of the relevant previous year – thus, the dis-allowance u/s.40a(i) applies only to the amounts ‘payable’ and not to those amounts which are already ‘paid’ – Decided against Revenue.
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