Section 14A disallowance confined to actual exempt income and section 80JJA deduction sustained on identical facts.

Disallowance under section 14A was confined to the amount of actual exempt income where the same approach had already been applied in the assessee's own earlier year and no distinguishing facts were shown. The Tribunal also accepted the deduction under section 80JJA for the relevant assessment years because the claim had been allowed in earlier years on identical facts and that view had been affirmed in appeal. On both issues, the Revenue's challenge failed and the relief granted to the assessee was sustained.

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Issues: (i) Whether the disallowance under section 14A could be restricted to the amount of actual exempt income earned. (ii) Whether the assessee was entitled to deduction under section 80JJA for the relevant assessment years.

Issue (i): Whether the disallowance under section 14A could be restricted to the amount of actual exempt income earned.

Analysis: The Tribunal noted that the issue had already been decided in the assessee's own case for an earlier assessment year, where the disallowance under section 14A was upheld only to the extent of actual exempt income. The impugned order followed that settled view and no contrary distinguishing facts were shown for the year under consideration.

Conclusion: The restriction of the disallowance to the extent of actual exempt income was upheld, and the Revenue failed on this issue.

Issue (ii): Whether the assessee was entitled to deduction under section 80JJA for the relevant assessment years.

Analysis: The Tribunal found that the claim had been allowed in the assessee's own case for earlier years on identical facts and that such allowance had been affirmed in appeal. No different factual matrix was shown for the years in appeal, and therefore no reason existed to depart from the earlier view.

Conclusion: The deduction under section 80JJA was allowed and the Revenue failed on this issue.

Final Conclusion: The Revenue's appeals were not successful, and the assessee's relief granted by the appellate authority was sustained for both assessment years.

Ratio Decidendi: Where an issue has been consistently decided in the assessee's own case on identical facts and no distinguishing circumstances are shown, the same view should ordinarily be followed; likewise, disallowance under section 14A was confined to the extent of actual exempt income on the facts of the case.

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