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2017 (10) TMI 1095 - AT - Income TaxDisallowance u/s 14A invoking Rule 8D - Held that:- On perusal of the dissatisfaction recorded by the Assessing Officer, we find that in addition to the issue of investment in mutual funds during the year under consideration, he has also referred use of resources and expenditure related to maintain, switching in and out of the funds. In our opinion, by making one factual mistake, other facts for recording the dissatisfaction required in terms of section 14A of the Act cannot be ignored. Accordingly, we reject the contention of the learned counsel challenging the prerequisite of recording the satisfaction under section 14A of the Act. We agree with the contention that disallowance under section 14A of the Act cannot exceed the exempt income earned by the assessee during the year under consideration, in view of the decision of the Hon’ble Delhi High Court in the case of Cheminvest Ltd, (2015 (9) TMI 238 - DELHI HIGH COURT) we restrict the disallowance under section 14A of the Act to ₹ 6,62,660/-.
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