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2021 (9) TMI 1125 - AT - Income TaxDisallowance u/s 14A - expenditure incurred in earning the dividend income - HELD THAT:- Revenue could not contradict the finding that the assessee has only earned exempt income to the tune of ₹ 148/-. The Revenue has also not rebutted the finding that no expenditure was incurred in earning for the dividend income. It is also contended that the Assessing Officer has not demonstrated the nexus between expenses incurred with the earning of the exempt income. The Hon'ble Supreme Court in the case of Godrej and Boyce Manufacturing Company Ltd. [2017 (5) TMI 403 - SUPREME COURT] held that what cannot be denied is that the requirement for attracting the provisions of section 14A(1) of the Act is proof of the fact that the expenditure sought to be disallowed had actually been incurred in earning the dividend income - Decided against revenue.
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