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2017 (9) TMI 1751 - AT - Income TaxAddition u/s. 14A r/w rule 8D - Held that:- We find that there are 3 limbs of disallowance in Rule 8D(2). (i) The direct expenses taken by AO from AY 2010-11 (last AY order) is wrongly typed. (ii) The AO’s expenditure of interest of ₹ 2,30,75,321/-. (iii) The assessee has made addition of ₹ 1,04,90,253/- u/s. 14A on earning of exempt income of ₹ 88,83,863/- which is more than the exempt income. Since the addition made by the assessee is reasonable and more than the exempt income earned, no further disallowance is necessary. Therefore, the addition of ₹ 4,15,24,709/- was rightly deleted by the CIT(A), which does not need any interference on our part, therefore, we affirm the impugned order on the issue in dispute involved in ground no. 1 and accordingly reject the same. - Decided against revenue.
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