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Issues: Whether disallowance under section 14A of the Income-tax Act, 1961 could exceed the exempt income earned by the assessee.
Analysis: The assessee had earned exempt income of Rs 3,502 and had made a suo motu disallowance. The Assessing Officer nevertheless applied Rule 8D and determined a higher disallowance. The Tribunal followed the settled principle that section 14A disallowance is restricted by the amount of exempt income and cannot be computed in excess of it.
Conclusion: The disallowance under section 14A was restricted to the exempt income of Rs 3,502, and the issue was decided in favour of the assessee.
Ratio Decidendi: Disallowance under section 14A of the Income-tax Act, 1961 cannot exceed the exempt income earned during the relevant year.