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2021 (12) TMI 821 - AT - Income TaxDisallowance u/s.14A - whether no satisfaction has been recorded by the AO as per requirement of Rule 8D, no such disallowance is warranted ? - HELD THAT:- As disallowance made by the AO and confirmed by ld. CIT(A) u/s 14A of the Act read with rule 8D of the Rules which is similar to the one involved in assessee's appeal for A.Y. 2012-13, which has already been decided by us. Since all the material facts relating to the said issue as involved in A.Y. 2014-15[2020 (12) TMI 188 - ITAT PUNE] are similar to A.Y. 2012-13, we follow the conclusion drawn by us in A.Y.2012-13 and delete the disallowance made by the Assessing Officer and confirmed by the ld. CIT(A) u/s.14A of the Act read with rule 8D of the Rules.- Decided in favour of the assessee. Claim of the assessee u/s.80IB/80IC on sale of scrap - HELD THAT:- As relying on own [2017 (12) TMI 1826 - ITAT PUNE] in favour of the assessee by virtue of .Madras High Court judgment in the case of M/s Fenner India Ltd [1998 (4) TMI 67 - MADRAS HIGH COURT] for the proposition that the profit on sale of scrap material since had a direct link or nexus with the industrial undertaking and therefore, it is eligible for deduction u/s 80IB, considering the similarity in language used in sections 80HH and 80IB of the Act, we are of the considered opinion that the assessee should succeed in this regard also.
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