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2019 (7) TMI 236 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - interest expenses and administrative expenses - net interest earned during year - assessee claimed that these are old investments and no expenditure incurred - HELD THAT - A perusal of the order of the ld.CIT(A) would reveal that the assessee has net interest income. It has shown interest income of Rs. 58, 38, 817/-therefore interest is not required to be computed for making disallowance. For buttressing our view point we rely upon judgment of Hon ble Gujarat High Court in the case of CIT Vs. Nirma Capital Credit P.Ltd. 8 2017 (9) TMI 485 - GUJARAT HIGH COURT . The ld.AR during the course of hearing also pointed out that if the calculation is being made on the basis of 0.5% of average value of the investment which has yielded dividend then total expenditure could be worked at Rs. 548/- only. Therefore considering the details submitted by the assessee as well as the fact that on similar investment no expenditure was disallowed in earlier years or in the subsequent year we are of the view that no disallowance is required u/s 14A in the present year also. This ground of appeal is allowed.
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