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2019 (1) TMI 1723 - MADRAS HIGH COURTDisallowance u/s 14A - expenditure incurred in relation to the income not includible in total income - as urged that in the absence of any actual dividend income earned by the assessee during the year in question, there was no question of any disallowance of debenture interest and finance charges to be made u/s 14A - HELD THAT:-There is no merit in this appeal filed by the Revenue and the entire edifice of the argument of the Revenue is without any foundation. The assessing authority misapplied the provisions of section 14A of the Act, which, in clear terms, stipulates that no deduction can be allowed in respect of expenditure incurred in relation to income, which does not form part of total income under the Act. In view of the clear fact found in the present case that the assessee did not earn any exempted income or dividend income on the equity shares held by it during this year, there was no question of disallowing any part of the debenture interest or finance charges, since the provisions under section 14A of the Act were not attracted at all. - Decided in favour of assessee
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