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    <title>2012 (2) TMI 384 - ITAT DELHI</title>
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    <description>Section 14A may disallow expenditure incurred in relation to exempt income even where no exempt income was received during the relevant year, provided a direct or indirect nexus between the expenditure and exempt-income investments is established. Substantial investments may support an inference of attributable expenditure, but require proper factfinding on managerial time and other related costs. Where the Assessing Officer and Commissioner (Appeals) have not adequately examined such expenditure, the disallowance requires fresh determination after hearing the assessee. Rule 8D may be used to compute the disallowance where warranted by that enquiry.</description>
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      <link>https://www.taxtmi.com/caselaws?id=210967</link>
      <description>Section 14A may disallow expenditure incurred in relation to exempt income even where no exempt income was received during the relevant year, provided a direct or indirect nexus between the expenditure and exempt-income investments is established. Substantial investments may support an inference of attributable expenditure, but require proper factfinding on managerial time and other related costs. Where the Assessing Officer and Commissioner (Appeals) have not adequately examined such expenditure, the disallowance requires fresh determination after hearing the assessee. Rule 8D may be used to compute the disallowance where warranted by that enquiry.</description>
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