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2022 (7) TMI 30 - AT - Income TaxDisallowance u/s 14A - as per AO Assessee has received exempt income and has also made investments in equity shares and bonds - HELD THAT:- We find that the assessee has given detailed submissions stating that the disallowance u/s 14A is not called for as no direct expenditure has been incurred to earn such exempt income and secondly interest disallowance is also not called for as sufficient interest free funds to the tune were available to cover up the investments of Rs. 6.64 crores as on 31.03.2013. AO simply brushed aside the assessee’s submission without recording any satisfaction about the correctness of the claim of the assessee proceeded to make the disallowance u/s 14A applying Rule 8D of the Rules. This Action of the ld. AO is not in consonance with the provision of Section 14A and therefore, we find no justification in the said disallowance made u/s 14A of the Act. We accordingly delete the said disallowance and allow the common issue raised by the assessee.
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