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    <title>2026 (1) TMI 365 - ITAT AHMEDABAD</title>
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    <description>Disallowance under s.14A r/w Rule 8D was in issue where the assessee admittedly earned no exempt income during the relevant AY. Applying the settled principle affirmed by the SC that s.14A cannot be invoked in the absence of exempt income, and consistent with HC authority that no disallowance lies where no exemption is claimed, the Tribunal held that no disallowance of interest or administrative expenses was permissible. Consequently, the addition made by the AO under s.14A r/w Rule 8D was deleted and the assessee&#039;s appeal was allowed.</description>
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    <pubDate>Tue, 06 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 365 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=784609</link>
      <description>Disallowance under s.14A r/w Rule 8D was in issue where the assessee admittedly earned no exempt income during the relevant AY. Applying the settled principle affirmed by the SC that s.14A cannot be invoked in the absence of exempt income, and consistent with HC authority that no disallowance lies where no exemption is claimed, the Tribunal held that no disallowance of interest or administrative expenses was permissible. Consequently, the addition made by the AO under s.14A r/w Rule 8D was deleted and the assessee&#039;s appeal was allowed.</description>
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