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2020 (9) TMI 769 - HC - Income TaxDisallowance u/s 14A read with Rule 8D - disallowance for deduction u/s 10A - HELD THAT:- No expenditure was incurred by them for earning the exempt income. The assessee were not able to substantiate that fact before the authorities or before the Tribunal. Both CIT(A) and the Tribunal re-appreciating the factual matrix and found that the investment during the year increased from Opening Balance of ₹ 3,21,68,40,000/- to Closing Balance of ₹ 5,17,93,70,000/-. Assessing Officer also found that the value of the assets also increased substantially to ₹ 1,84,18,32,000/- from ₹ 1,76,96,30,000/- and therefore applied Rule 8D and made additions under Section 14A of the Act and we find no error in the order of the Assessing Officer as confirmed by the CIT(A) and the Tribunal. Accordingly the Substantial Question of Law No.1 is answered against the assessee. Computing deduction under Section 10A - Exclusion of foreign currency from the 'Export Turnover' - HELD THAT:- In the case of M/s.Renault Nissan Technology & Business Centre India Private Limited [2020 (8) TMI 19 - MADRAS HIGH COURT] this Court has considered the Substantial Question of Law as to whether the Tribunal erred in holding that the expenditure incurred in foreign exchange by the assessee therein was to be excluded from the 'Export Turnover' for the purpose of computing deduction under Section 10AA of the Act and the question was answered in favour of the assessee
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