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2014 (6) TMI 735 - ITAT DELHILevy of penalty u/s 271(1)(c) of the Act – Disallowance u/s 14A of the Act – Held that:- The assessee has not incurred any administrative or interest expenditure for managing such investment - The expenses claimed in the profit & loss account have no relation with the earning of dividend income – the AO did not accept the assessee’s contention but computed the disallowance u/s 14A read with Rule 8D - merely because certain disallowance is made u/s 14A rejecting the assessee’s contention that no disallowance is called for would not be sufficient to levy the penalty u/s 271(1)(c) - there is no allegation of the Revenue that the assessee furnished any details which are found to be false or inaccurate - Merely because some disallowance is computed as per the formula prescribed under Rule 8D, it cannot be presumed that the assessee has concealed the income or furnished inaccurate particulars of income – Relying upon CIT Vs. Reliance Petroproducts Pvt.Ltd. [2010 (3) TMI 80 - SUPREME COURT] – Decided in favour of Assessee.
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