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2019 (8) TMI 653 - GUJARAT HIGH COURTDisallowance u/s 14A r.w. Rule 8D - no exempt income earned during the year - HELD THAT:- Tribunal concurred with the findings recorded by the CIT(A) that Section 14A can be invoked only if the assessee seeks to square off the expenditure against the income which does not form the part of the total income under the Act and in such circumstances, Section 14A of the Act could not have been invoked, more particularly, when no exempt income claim was earned in the relevant assessment years. The Tribunal has relied on various decisions including the decision of this court in the case of Corrtech Energy Private Limited, [2014 (3) TMI 856 - GUJARAT HIGH COURT] Having regard to the concurrent findings recorded by the two Revenue Authorities, we are not inclined to disturb such findings. In our view, there is no substantial question of law involved in the present Tax Appeal.
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