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2017 (11) TMI 1880 - AT - Income TaxDisallowance u/s 14A - assessee has no exempt income during the period relevant to the assessment year under consideration - HELD THAT:- The assessee has not made any investment during the year under consideration. There is no dispute that all investment has been made in the subsidiaries companies as strategic investment so as to get controlling interest in such subsidiaries. The Hon’ble Delhi High Court in case of Cheminvestment Ltd. Vs. CIT [2015 (9) TMI 238 - DELHI HIGH COURT] held that, if there is no dividend income, then there cannot be any correspondence allowance. We have noted that the assessee has voluntary disallowed ₹ 13.10 Lakhs as administrative expenses for investment in its associate companies/subsidiaries. The assessee has placed on record fund flow statement (Page 33 of PB), which clearly show that the assessee has sufficient own interest free fund of ₹ 1,26,289.65/- Lakhs as on 31.03.2012. Thus, in our considered view there was no justification for making disallowance as per the provisions of section 14A r.w. Rule 8D.
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