2020 (12) TMI 613

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..... ntial question of law raised for consideration was answered against the Revenue by the Hon'ble Division Bench of this Court in the case of Marg Ltd. [ 2020 (10) TMI 102 - MADRAS HIGH COURT] wherein it was held that the disallowance under Rule 8D of the Income Tax Rules, 1962 read with Section 14A of the Act could never exceed exempted income earned by the assessee during the particular assess .....

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..... ' for brevity) respectively for the assessment years 2013-14 and 2012-13. 2. The Revenue has filed these appeals by raising the following substantial question of law: Whether, on the facts and circumstances of the case and in law, the Tribuanl was correct in directing the Assessing Officer to delete the disallowance as to exempted income was earned by the assessee without appreciating .....

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..... uld never exceed exempted income earned by the assessee during the particular assessment year and that the same could be computed as per Rule 8D of the said Rules only after recording satisfaction by the Assessing Authority. 5. In the earlier decision of this Court, to which, one of us (TSSJ) was a party, in the case of CIT Vs. Tidel Park Ltd. [TCA. Nos.732 and 733 of 2018 dated 07.7.2020 .....

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