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TMI Blog2019 (4) TMI 1529X X X X Extracts X X X X X X X X Extracts X X X X ..... (iii) of sub-rule (2) of Rule 8D Held that:- Hon ble Delhi High Court in the case of Cheminvest Ltd. vs CIT [ 2015 (9) TMI 238 - DELHI HIGH COURT] wherein it was held that no disallowance u/s 14A could be made if no exempt income was actually earned by the assessee in the relevant year. Since no exempt income in respect of dividend was actually earned by the assessee during the year under cons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ompany which is engaged in the business of property development. The return of income for the year under consideration was filed by it on 30.03.2015 declaring a total income of ₹ 6,54,20,080/-. As noted by the AO during the course of assessment proceedings, the assessee company had made a substantial investment in the shares of other group companies. According to the AO, even if no dividend ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wance u/s 14A could be made only on account of other expenses as per clause (iii) of sub-rule (2) of Rule 8D. He accordingly directed the AO to restrict the disallowance u/s 14A only to that extent. Aggrieved by the order of the Ld. CIT(A), the Revenue has preferred this appeal before the Tribunal. 4. We have heard the arguments of both the sides and also perused the relevant materi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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