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2021 (9) TMI 2 - ITAT BANGALOREDisallowance u/s 14A - assessee argued no exempted income was earned during the relevant assessment year - HELD THAT:- A.O. while making the disallowance u/s 14A had relied on the Special Bench order of the Tribunal in Cheminvest Ltd. [2009 (8) TMI 126 - ITAT DELHI-B] but the said order of the Tribunal was reversed by the Hon’ble Delhi High Court 2015 (9) TMI 238 - DELHI HIGH COURT] wherein as clearly held that unless exempted income earned during the relevant assessment year, there cannot be any disallowance u/s 14A . Thus since no exempted income is earned during the relevant assessment year, no disallowance u/s 14A of the I.T.Act could be resorted to - Decided against revenue.
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