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2019 (2) TMI 1332

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....espondent P.C. 1. The appeal is admitted for consideration on following question of law : (i) On the facts and in the circumstance of the case and in law, the Tribunal is not justified in holding that the distribution network, material supply contract and brand use are eligible for depreciation, it has failed to specify any reason as to how it falls within the clause "any other business or comm....

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....the Assessing Officer under Section 14A of the Income Tax Act, 1961 r/w Rule 8D of the Rules of the expenditure incurred by the assessee for earning exempt income. The Tribunal by the judgment which is impugned in this appeal held that the assessee had not earned any exempt income during the year under consideration. The Tribunal, therefore, followed the decision of Delhi High Court in case of CIT....

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....t earned any exempt income during the year under consideration. After consideration of Section 14A, the Delhi High Court followed decisions of certain other High Courts. Section 14A of the said Act provides that for the purpose of computing the total income, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total ....