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2021 (8) TMI 65 - AT - Income TaxDisallowance u/s 14A - AO was of the opinion that to earn exempt income, the assessee must have incurred some expenditure and accordingly, computed the disallowance u/s 14A of the Act r.w.r 8D - HELD THAT:- As decided in own case [2017 (11) TMI 1545 - ITAT DELHI] AO has not even identified any specific item of expense he merely says that explanation of assessee is not correct as huge investment is made - There is no satisfaction of terms of s. 14A read with Rule 8 D. Copy of order for AY 08-09 is also placed as per which no disallowance u/s 14A was made, hence assessee is right in submitting that disallowance is also against the principle of consistency in the absence of any facts. - Decided in favour of assessee.
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