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2018 (2) TMI 1652 - HC - Income TaxDisallowance u/s 14A - grievance of the Revenue is that Rule 8D of the Rules ought to be applied in the facts of the present case - Held that:- We find that the issue as raised by the Revenue is concluded against it by the decision of this Court in CIT v/s. HDFC Bank Ltd.[2014 (8) TMI 119 - BOMBAY HIGH COURT] wherein it has been held that where the Assessee has its own funds, no occasion to disallow any part of interest payment made by the Assessee under Section 14A can arise. Further, we also note that the Assessing Officer has not recorded his non-satisfaction with the claim for disallowance made by the Respondent before proceeding to apply Rule 8D of the Rules. Further, we find that the disallowance of expenditure to the extent of 5% of the dividend income earned, is reasonable. No substantial question of law
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