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2018 (5) TMI 1944 - AT - Income TaxDisallowance u/s 14A - no exempt income was earned - HELD THAT:- There is no dispute with regard to the fact that the assessee-company did not earn any exempt income during the years under consideration. In fact, in the grounds, duly authorised by the CIT, the Revenue has not objected to the claim of the assessee that no exempt income was earned during the years under consideration. Identical issue had come for adjudication before the ITAT Hyderabad in number of cases wherein the Bench observed that section 14A refers to disallowance of expenditure “in relation to income” which pre-supposes existence of income in the form of dividend as otherwise section 14A cannot be pressed into service. - Decided against revenue.
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