TMI Blog2017 (7) TMI 1067X X X X Extracts X X X X X X X X Extracts X X X X ..... gh Court in the case of Joint Investment Private Limited [2015 (3) TMI 155 - DELHI HIGH COURT] held that by no stretch of imagination can section 14A or Rule 8D be interpreted so as to mean that entire tax exempt income is to be disallowed. In the case on hand since the assessee received dividend income of ₹ 1,70,000/- as recorded in the Assessment Order the disallowance should not be mor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ever, the notice returned unserved with postal endorsement that the addressee has left . Hence we proceed to dispose of this appeal on hearing the Ld.DR. 3. The Ld.DR submits that the Assessing Officer while completing the assessment by invoking the provisions u/s 14A disallowed ₹ 54,66,813/- while computing the income under normal provisions of the Act as well as the book profits u/s 11 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT v. Empire Package Private Limited in ITA.No. 415/2015 held that disallowance should not exceed exempt income. In the case on hand since the assessee received dividend income of ₹ 1,70,000/- as recorded in the Assessment Order the disallowance should not be more than ₹ 1,70,000/-. Thus we direct the Assessing Officer to restrict the disallowance to the extent of dividend income i.e. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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