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2021 (8) TMI 870 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - HELD THAT:- As decided in JOINT INVESTMENTS PVT LTD [2015 (3) TMI 155 - DELHI HIGH COURT] by no stretch of imagination can s. 14A or r. 8D be interpreted so as to mean that the entire tax exempt income is to be disallowed. The window for disallowance is indicated in s. 14A, and is only to the extent of disallowing expenditure "incurred by the assessee in relation to the tax exempt income - thus we direct the Assessing Officer to restrict the disallowance to the extent of exempt income. Net off interest income with interest expenditure - HELD THAT:- It is an undisputed fact that the assessee has parked its surplus funds in fixed deposits of the bank from which it earned interest income - we find that the assessee has also paid interest to the bank. In our considered opinion, interest earned has to be netted off with interest expenditure. We, accordingly, direct the Assessing Officer to net off interest income with interest expenditure.
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