TMI Blog2021 (1) TMI 1260X X X X Extracts X X X X X X X X Extracts X X X X ..... r exemption in the income from payment of tax in disallowance could be made under Section 14A of the Act. Addition on account of disallowance u/s. 14A r.w Rule 8D while computing Book Profit u/s. 115JB - HELD THAT:- The second question would also not survive once the view is taken that there could not have been any disallowance under Section 14A read with Rule 8D of the Act. In such circumsta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he A.Y. 201516. 2. The Revenue has proposed the following substantial questions of law for consideration of this Court : [A] Whether the Appellate Tribunal has erred in law and on facts in deleting the addition of Rs.13,55,80,000/made on account of disallowance u/s. 14A of the Act r.w. Rule 8D? [B] Whether the Appellate Tribunal has erred in law and on facts in deleting the addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n any disallowance under Section 14A read with Rule 8D of the Act. In such circumstances, there is no question of computing the Book Profit under Section 115JB of the Act. In other words, the expenses incurred to exempt the income cannot be added for computing the Book Profit under Section 115JB of the Act. 5. In view of the aforesaid, this appeal fails and is hereby dismissed. We may clarify t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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