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2019 (5) TMI 314 - AT - Income TaxDisallowance u/s 14A r.w.Rule 8D - assessee did not earn exempt income in the impugned assessment years - HELD THAT:- The expenditure in the form of investment was incurred by the appellant. It is also equally not in dispute that there is no exempt income in the form of dividend received by the appellant for the respective assessment years. There is no controverting material before the AO regarding the exempted income. The overwhelming judicial view regarding disallowance u/s.14A r.w.r. 8D is that "no disallowance can be made in the absence of deemed dividend". See M/S. REDINGTON (INDIA) LTD. VERSUS THE ADDITIONAL COMMISSIONER OF INCOME TAX [2017 (1) TMI 318 - MADRAS HIGH COURT] and M/S. CHETTINAD LOGISTICS PVT. LTD. [2017 (4) TMI 298 - MADRAS HIGH COURT] - Decided in favour of assessee.
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