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2021 (2) TMI 1298 - AT - Income TaxDisallowance u/s 14A - assessee offered a suo-motu disallowance towards the expenditure to earn dividend income - As specifically contended before the AO and the ld. CIT(A) that no borrowed funds were utilized for the purpose of making the investments which yielded the dividend income for the year under consideration - HELD THAT:- The lower authorities without considering the submissions made in proper perspective had proceeded to make the disallowance. On perusal of the material it is clear that no borrowings were utilized for the purpose of making the investments which yielded the dividend income. The borrowings shown in the books of account were made for specific purpose. In the absence of evidence to the contrary, it cannot be presumed that the borrowed funds have been utilized for the purpose of making the investments which yielded the dividend income. Therefore, we are of the considered opinion that no further disallowance u/s 14A of the Act is warranted. Accordingly, we direct the Assessing Officer to delete the addition made u/s 14A of the Act. Appeal of assessee allowed.
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