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2021 (1) TMI 1260 - HC - Income TaxDisallowance u/s. 14A of the Act r.w. Rule 8D - HELD THAT:- The first question is covered by a decision of this Court in the case of CIT Vs. Corrtech Energy Pvt. Ltd. [2014 (3) TMI 856 - GUJARAT HIGH COURT] The view taken therein is that, when the assessee has not made claim for exemption in the income from payment of tax in disallowance could be made under Section 14A of the Act. Addition on account of disallowance u/s. 14A r.w Rule 8D while computing Book Profit u/s. 115JB - HELD THAT:- The second question would also not survive once the view is taken that there could not have been any disallowance under Section 14A read with Rule 8D of the Act. In such circumstances, there is no question of computing the Book Profit under Section 115JB of the Act. In other words, the expenses incurred to exempt the income cannot be added for computing the Book Profit under Section 115JB of the Act. We may clarify that since the disallowance under Section 14A itself has been deleted, therefore, there is no question of adding back under Section 115JB
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