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2019 (7) TMI 1983 - SC ORDERDisallowance u/s 14A - as per Revenue he could disallow the expenditure even there is no income i.e., dividend by taking recourse to Rule 8D - as decided by HC there is no dispute that no income i.e., dividend, which did not form part of total income of the Assessee was earned in the relevant assessment year and the addition made by by relying upon Section 14 A was completely contrary to the provisions of the said Section. HELD THAT:- There is delay of 324 days in filing the Review Petition for which no satisfactory explanation has been given. Even otherwise, we do not find any merit in the Review Petition. The Review Petition is dismissed on the ground of delay as well as merits.
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