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2017 (4) TMI 1557 - AT - Income TaxDisallowance u/s 14A r.w.r.8D - assessee argued 'appellant' has no income which is claimed as exempt and therefore, legally no disallowance under section 14A is warranted - HELD THAT:- We find that it is an undisputed fact that the assessee has not earned any dividend or any kind of exempt income during the year. Whence there is no exempt income claimed by the assessee, then the ratio laid down by the Hon’ble Jurisdictional High Court in Cheminvest Ltd. vs. CIT (2015 (9) TMI 238 - DELHI HIGH COURT] that if the assessee has not earned any exempt income or when there is no actual receipt of any income which does not form part of the total income, no disallowance u/s 14A can be made, is clearly applicable here. We therefore, hold no disallowance u/s 14A can made in this year, because, admittedly there is no exempt income earned by the assessee in this year. - Decided in favour of assessee.
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