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    <title>2021 (5) TMI 240 - ITAT MUMBAI</title>
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    <description>Disallowance of expenditure under section 14A read with Rule 8D cannot be sustained where the assessee has not earned any exempt income during the relevant year. The Tribunal applied the settled principle that section 14A operates only in relation to expenditure incurred to earn income not forming part of total income, and since the absence of exempt income was undisputed, no corresponding disallowance could arise. The deletion of the addition by the Commissioner (Appeals) was therefore upheld.</description>
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      <description>Disallowance of expenditure under section 14A read with Rule 8D cannot be sustained where the assessee has not earned any exempt income during the relevant year. The Tribunal applied the settled principle that section 14A operates only in relation to expenditure incurred to earn income not forming part of total income, and since the absence of exempt income was undisputed, no corresponding disallowance could arise. The deletion of the addition by the Commissioner (Appeals) was therefore upheld.</description>
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