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2020 (10) TMI 607 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - Addition with regard to the normal computation of income as well as the computation of book profit u/s 115JB - HELD THAT:- There is no dispute in these appeals that the assessee did not earn any exempt income. Also there is no dispute that the assessee did not make any claim for exemption. That when there is no exempt income earned by the assessee, no disallowance u/s 14A of the Act can be made is no longer res integra. There is no exempt income earned by the assessee, no disallowance under Section 14A of the Act can be made. Similar is the decision in Pr. CIT v. M/s Ballarpur Industries Ltd. [2016 (10) TMI 1039 - BOMBAY HIGH COURT] and Winsome Textiles Industries Ltd. [2009 (8) TMI 220 - PUNJAB AND HARYANA HIGH COURT] Also in the case of ACIT v. Vireet Investment (P.) Ltd. [2017 (6) TMI 1124 - ITAT DELHI] has held that computation under clause (f) of Explanation 1 to section 115JB(2) is to be made without resorting to computation as contemplated u/s 14A r.w. Rule 8D. - Decided against revenue.
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