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TMI Blog2018 (4) TMI 1804X X X X Extracts X X X X X X X X Extracts X X X X ..... t appeal has been filed by the Revenue against the order of the Ld. CIT(A)-2, Ludhiana dt. 09/08/2017. 2. The Revenue has raised only one ground in this appeal which reads as under: 1. Whether upon facts and circumstances of the case, the Ld. CIT(A) was justified in deleting the disallowance under section 14A of the Income Tax Act, 1961, r.w. Rule 8D(ii). 3. Brief facts of the case are that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sions are mandatory irrespective of the income earned or not out of the investments. Once the investments are made the assessee must have incurred expenses for such an activity. 6. The Ld. AR argued that in any case the disallowance cannot exceed the tax free income earned. 7. We have heard the ld. Representatives of both the parties and perused the material available on record. The matter has b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the Rule 8D of the Rules being mandatory, disallowance as per Rule 8D has be made even in cases where no tax free income has ,ed or where tax free income earned is lesser than the nt computed as per Rule 8D of the Rules. In our w, the proposition laid down by various High Courts as mentioned hereinabove is applicable in the present case with full force. In view of this, we direct the Assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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