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2022 (2) TMI 1382 - AT - Income TaxDisallowance u/s. 14A - assessee earned dividend income which was claimed as exempt u/s. 10 (34) / 10 (35) - Suo moto disallowance made by assessee - HELD THAT:- This Tribunal in A.Y. 2010-11 [2022 (7) TMI 374 - ITAT DLEHI] has considered a similar disallowance as held for the purpose of computing the disallowance u/s. 14A of the Act only such investments which yielded exempt income during the year should be taken into consideration, but not the entire investment. Going by that principle, we find that during the year, the investment in Karnataka Bank Ltd. alone yielded dividend income. Tribunal accepted the contention of the assessee as far as the investment in shares of Karnataka Bank Ltd. was concerned. It is, therefore, clear that no disallowance could be made towards interest expense u/r. 8D(2)(ii) of the rules. Disallowance of SAR expenses written back in the current year - HELD THAT:- As decided in [2020 (9) TMI 141 - ITAT DELHI] the issue-in-dispute of SAR expenses as revenue in nature is covered in favour of the assessee. Respectfully following the above decisions, we set aside the order of the learned CIT(A) and delete the addition.
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