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TMI Blog2023 (6) TMI 617X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax [ 2015 (3) TMI 155 - DELHI HIGH COURT ] as held window for disallowance is indicated in Section 14A and is only to the extent of disallowing expenditure incurred by the assessee in relation to the tax exempt income . This proportion or portion of the tax exempt income surely cannot swallow the entire amount. In this case as well, the admitted position is that the dividend income, exempt u/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pplication filed on behalf of the appellant seeking condonation of delay of 49 days in filing the appeal] 1. This is an application moved on behalf of the appellant/revenue seeking condonation of delay in filing the appeal. 1.1 According to the appellant/revenue, there is a delay of 49 days. 2. Mr Rohit Jain, who appears on behalf of the respondent/assessee, says that he does not oppos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 94 (Delhi) wherein, inter alia, the following observations have been made : 9. .... The third, and in the opinion of this court, important anomaly which we cannot be unmindful is that whereas the entire tax exempt income is Rs.48,90,000/-, the disallowance ultimately directed works out to nearly 110 per cent of that sum, i.e., Rs.52,56,197. By no stretch of imagination can Section 14A or rule ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,63,13,621/-. Clearly, the disallowance sought to engulf the exempt dividend income earned by the respondent/assessee. 12. The ratio of the aforementioned judgment therefore, applies on all fours. 13. According to us, no substantial question of law arises for our consideration in the present appeal. 14. The appeal is, accordingly, closed. 15. Parties will act based on the digitally sig ..... X X X X Extracts X X X X X X X X Extracts X X X X
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