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2018 (3) TMI 1718 - HC - Income TaxDisallowance u/s 14A - HELD THAT:- Assessee had offered ₹ 10,46,264/- as a disallowance under Section 14A of the Act towards interest free income. AO however rejected the amount and made a disallowance of over ₹ 4.13 crores approximately upon application of Rule 8D(2)(ii) and 8D(2)(iii). CIT(A) restricted the disallowance amounting to ₹ 9,00,621/-by holding that the application of Rule 8D(2)(ii) of the Act was not called for. ITAT confirmed that order. This Court has considered the Revenue’s submissions. Clearly, the AO had fallen into error in overlooking that the assessee had deployed its own substantial part of funds to derive a tax exempt income. In these circumstances, the findings of the lower Appellate Authorities are justified.
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