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2021 (10) TMI 572 - AT - Income TaxQuantum of deduction allowed u/s 80IA - assessee has declared loss under the head “income from business” and it has earned interest income which was declared under the head Income from other sources - A.O. took the view that the deduction u/s 80IA of the Act has been allowed against interest income assessed under “Income from other sources” - HELD THAT:- The Hon’ble Supreme Court in the case of CIT vs. Reliance Energy Ltd (2021 (4) TMI 1237 - SUPREME COURT] held that there is no limitation on deduction admissible under Section 80-IA of the Act to income under the head ‘business’ only. Hence the view expressed by the AO in the instant case was not right and accordingly, we confirm the order passed by Ld CIT(A) on this issue. Disallowance made u/s 14A - CIT(A) restricted the disallowance to the amount of exempt income by following the decision rendered by Hon’ble Karnataka High Court in the case of Pragathi Krishna Grameena Bank [2018 (6) TMI 1283 - KARNATAKA HIGH COURT ] and also various Tribunal decisions - HELD THAT:- We notice that the Ld CIT(A) has decided this issue following the binding decision of Hon’ble jurisdictional Karnataka High Court. Hence we do not find any reason to interfere with his decision rendered on this issue.
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