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2014 (5) TMI 697

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..... Mfg. Co. Ltd. v. Dy. CIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] - it is not only the investment in shares, yielding dividend, but also that in the partnership firm that would stand to be reckoned for the purpose of the relevant investment in computing the disallowance under rule 8D, i.e., where no interest income is contracted for, so that the only income that could arise from the said investment .....

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..... ) of the Income Tax Act, 1961 ( the Act hereinafter) for the assessment year (A.Y.) 2009-10 vide order dated 21.12.2011. 2. Opening the arguments for and on behalf of the assessee, it was submitted by the ld. Authorized Representative (AR), the assessee s counsel, that the only issue arising in the instant appeal is with regard to the disallowance made in the sum of Rs.7,48,846/- u/s.14A of th .....

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..... ply. The assessee has, in fact, earned a nominal dividend at Rs. 14,896/- for the current year. The ld. Departmental Representative (DR), on the other hand, would rely on the orders of the authorities below, stating that there is nothing on record to substantiate the claims being now raised by the assessee before the tribunal. 3. We have heard the parties, and perused the material on record. .....

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..... ly the investment in shares, yielding dividend, but also that in the partnership firm that would stand to be reckoned for the purpose of the relevant investment in computing the disallowance under rule 8D, i.e., where no interest income is contracted for, so that the only income that could arise from the said investment is the share of profit, which is taxexempt. As regards the inclusion of bank F .....

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