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2017 (6) TMI 864 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - Held that:- DR did not controvert the claim of the assessee that no exempt income was earned by the assessee, which does not form part of the total income, thus, we find force in the argument of the ld. counsel for the assessee and the conclusion of the Ld. Commissioner of Income Tax (Appeal), as in the present case, the assessee has not earned any tax free income, hence the provision of section 14A of the Act, will not be applicable. For Assessment Year 2009-10 we find that the assessee has not claimed any administrative expenses, as deduction, in its computation of income and the expenses of ₹ 69,70,878/- were met out from the group companies, which were recovered from them and showed as other income. The assessee has not claimed any expenses as deduction, thus, there is no question of any disallowance u/s 14A of the Act. It is also noted that, as claimed by the assessee, in respect of investment in group companies, the assessee has not received any dividend income and these investments were made in earlier Financial Years out of owned funds and thus the assessee has not incurred any expenditure in relation to the investment in group companies.
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