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2016 (4) TMI 849 - AT - Income TaxDisallowance u/s 14A - Held that:- earlier noticed that the dividend received/receivable from PCIL and VBL alone are exempt. These investments have been made in the earlier years and further the investment made in PCIL was a strategic investment. The assessee has received dividend income of ₹ 2,000/- only during the year under consideration and the said dividend income has also been directly credited to the bank account of the assessee. Considering the smallness of the dividend income and also considering the fact, that the investment in shares have been made in the earlier years, we are of the view that there is merit in the contentions of the assessee that it did not incur any expenditure in relation to the dividend income. Further, as contended by Ld A.R, the AO did not reject the contentions of the assessee by having regard to the accounts of the assessee. Hence, we find no reason for invoking the provisions of Rule 8D of the I.T. Rules in the hands of the assessee for the year under consideration. Accordingly, we set aside the order of the CIT(A) on this issue and direct the Assessing Officer to delete the disallowance made u/s. 14A - Decided in favour of assessee Rejection of deduction claimed u/s. 80IA - Held that:- We have earlier noticed that both the AO as well as the Ld CIT(A) has made some more observations to support the rejection of the claim for deduction u/s 80IA of the Act. The Ld A.R submitted that the assessee shall be in a position to satisfy the AO with regard to those observations also. Accordingly, we are of the view that the entire matters relating to the deduction u/s 80IA including the various adverse features noted down by the AO/CIT(A) requires fresh examination.
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