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2017 (12) TMI 808 - ITAT COCHINAddition u/s 14A - Held that:- Disallowance as contemplated u/s 14A of the Act cannot exceed exempt income. Therefore, we direct the A.O. to restrict the disallowance worked out under Rule 8D(2)(iii) to the extent of exempt income earned by the assessee for the relevant period. Disallowance of amortization of software development expenses - assessee filed a rectification application u/s 154 seeking rectification of deletion made by the A.O. towards disallowance of amortization of software expenses as the CIT(A) has allowed the claim of the assessee with regard to depreciation on total block of assets - Held that:- We find that the issue of amortization of software development expenses and depreciation on capital expenditure has been dealt by the CIT(A) in his appellate order and allowed relief to the assessee on both the counts. We further noted that the CIT(A) in his rectification order dated 09.12.2016 rectifying the said mistake had allowed relief only in respect of claim of depreciation on software expenditure and confirmed the addition made by the A.O. towards disallowance of amortization of software expenditure. Therefore, we are of the view that the ground raised by the Revenue challenging deletion made by the CIT(A) becomes infructuous and hence the same is dismissed.
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