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2015 (10) TMI 1623 - ITAT AHMEDABADDisallowance under section 14A - contention of the assessee is that no expenditure was incurred in relation to exempt income and no material has been brought on record to show that any actual expenditure was incurred in relation to earning of exempt income - Held that:- Held that:- We find that in the instant case, the Revenue has not brought any positive material on record to show that the assessee actually incurred any expenses in relation to earning of exempt income. In our considered view, before making disallowance under section 14A, it was imperative on the part of the Revenue to bring some material on record to show that the assessee actually incurred any expenditure in relation to exempt income. In the absence of the same, in view of the decision of in the case of CIT Vs. Torrent Power Ltd., (2014 (6) TMI 185 - GUJARAT HIGH COURT ) the disallowance confirmed by the CIT(A) is not sustainable. - Decided in favour of assessee.
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