TMI Blog2020 (12) TMI 290X X X X Extracts X X X X X X X X Extracts X X X X ..... there was no exempt income attributable in the hands of the assessee. Therefore, applying Section 14A read with Rule 8D is not appropriate on part of Assessing Officer. CIT(A) rightly held that no expenditure can be disallowed against Nil exempt income and this view is also supported by the decision of the Jurisdictional High Court of Delhi in case of CIT Vs. Holcim India Pvt. Ltd. [ 2014 (9) T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /2017 passed by CIT (A)-4, New Delhi for Assessment Year 2013-14. 2. The grounds of appeal are as under:- 1. On the facts and in the circumstances of the case, the Ld.CIT(A) has erred in law in deleting the addition of ₹ 3,81,25,375/- made on account of disallowance u/s 14A read with Rule 8D of the Act by ignoring the fact that the assessee has incurred huge expenses in relation to th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment proceedings and passed final assessment order on 30/1/2017 u/s 143(3) read with Section 144C and assessed loss was determine at ₹ 71,33,63,400/- after making the following adjustments:- 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. The Ld. DR submitted that the CIT(A) erred in delet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 71,33,66,400 6. The Ld. AR relied upon the order of the CIT(A) and further submitted that no exempt income was earned during the present assessment year and no expenditure was incurred. The Ld. AR relied upon the decision of the Hon ble Delhi High Court in case of CIT Vs. Holcim India Pvt. Ltd. 272 CTR 282 and Cheminvest Ltd. reported at 371 ITR 23. 7. We hav ..... X X X X Extracts X X X X X X X X Extracts X X X X
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