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2020 (1) TMI 619 - AT - Income TaxExemption u/s 10(34) without disallowing any expenditure u/s 14A - HELD THAT:- Neither any change of circumstances nor any decision of any higher forum is brought to our notice by the Revenue. Hence while respectfully following the above consistent view taken by the Tribunal in assessee’s own case for the earlier assessment years [2019 (4) TMI 1769 - ITAT DELHI] we allow ground of assessee’s appeal and direct the Assessing Officer to allow exemption to the assessee under section 10(34) of the Act without disallowing any expenditure under section 14A of the Act. Addition on account of income from sale of investment to be deleted as relying on own case [2018 (1) TMI 845 - ITAT DELHI] Provision of bad debts - HELD THAT:- As relying on own case [2018 (1) TMI 845 - ITAT DELHI] wherein examined the contention of the learned DR that the assessee himself added back the royalty while computing the shareholders income. This implies that the assessee has accepted the view of the Revenue that the income in the shareholders a/c has to be computed under the normal provisions of the computation of income in Income Tax Act. Royalty paid by the assessee in our view cannot be regarded to be an expense relating to the life insurance business. There is nothing wrong caused to the Revenue as Royalty cannot be regarded to be liability incurred for life insurance business. We therefore set aside order of CIT(A) on this issue and delete the enhancement made by CIT(A).
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