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    <title>2020 (6) TMI 169 - ITAT CUTTACK</title>
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    <description>Disallowance under section 14A read with Rule 8D(2) was held unsustainable where the Assessing Officer did not record satisfaction that expenditure had been incurred to earn exempt dividend income. The rule-based formula could not replace the statutory requirement of first identifying actual expenditure attributable to exempt income. The text also notes that the assessee had not claimed the dividend income as exempt during the year, supporting the conclusion that no disallowance was warranted on these facts. The disallowance was therefore deleted in favour of the assessee.</description>
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      <title>2020 (6) TMI 169 - ITAT CUTTACK</title>
      <link>https://www.taxtmi.com/caselaws?id=395794</link>
      <description>Disallowance under section 14A read with Rule 8D(2) was held unsustainable where the Assessing Officer did not record satisfaction that expenditure had been incurred to earn exempt dividend income. The rule-based formula could not replace the statutory requirement of first identifying actual expenditure attributable to exempt income. The text also notes that the assessee had not claimed the dividend income as exempt during the year, supporting the conclusion that no disallowance was warranted on these facts. The disallowance was therefore deleted in favour of the assessee.</description>
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      <pubDate>Fri, 05 Jun 2020 00:00:00 +0530</pubDate>
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