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2019 (6) TMI 1633 - AT - Income TaxDisallowance u/s 14A - assessee suo moto made disallowance - HELD THAT:- The issue is now covered, in favour of the assessee, by a coordinate bench decision in the case of DCIT vs. Greenland Infracon Pvt Ltd [2018 (11) TMI 1415 - ITAT AHMEDABAD] section 14A of the Act can be triggered only if assessee seeks to square off expenditure against the income which does not form part of total income under the Act and Section 14A of the Act cannot be invoked where no exempt income was earned in the relevant assessment years.No potency in the argument laid on behalf of the Revenue that the CIT(A) allegedly committed error in granting total relief in the matter of disallowance u/s 14A. In our considered view, the action of the CIT(A) in granting relief under s.14A on account suo moto disallowance by the assessee and thereby granting relief higher than claimed in the return of income cannot be faulted in law. Appeal of the Revenue is dismissed.
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