TMI Blog2020 (8) TMI 123X X X X Extracts X X X X X X X X Extracts X X X X ..... (2) - CIT- A deleted the addition - HELD THAT:- Since it is an admitted fact that no dividend income is earned by assessee in assessment year under appeal which fact is clearly mentioned in the Orders of the authorities below, therefore, it is an undisputed fact that assessee company has not received any dividend income in assessment year under appeal. This issue has also been decided in case o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A)-7, New Delhi, Dated 12.06.2017, for the A.Y. 2014-2015, challenging the deletion of disallowance of ₹ 4,34,68,736/- made by A.O. under section 14A read with Rule 8D of I.T. Act, 1961. 2. We have heard the Learned Representatives of both the parties through video conferencing and perused the Orders of the authorities below. 3. During the year under consideration assessee company is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee challenged the addition before the Ld. CIT(A). The assessee apart from challenging the addition on merit as well as submitted before the Ld. CIT(A) that since assessee company did not receive any dividend income during the year, no further disallowance under section 14A can be made in the case of assessee in the light of Judgment of jurisdictional Delhi High Court in cases of Commissioner o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned, addition could be made under section 14A because the A.O. is bound by the mandatory provisions of Rule 14A read with Rule 8D(2) of the I.T. Act, 1961. Since it is an admitted fact that no dividend income is earned by assessee in assessment year under appeal which fact is clearly mentioned in the Orders of the authorities below, therefore, it is an undisputed fact that assessee company has ..... X X X X Extracts X X X X X X X X Extracts X X X X
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