2017 (11) TMI 126

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....nue against an order dated 9th February 2017 passed by the Income Tax Appellate Tribunal ("ITAT") in ITA No. 4088/Del./2014 for the Assessment Year ("AY") 2011-12. 2. The question sought to be urged by the Revenue is as under: "Whether on facts and in the circumstances of the case the Ld. ITAT was correct in law in holding that the Disallowance U/s 14A has to be limited 10 the quantum ....

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....ely unnoticed by the CIT (A) and the ITAT. The third, and in the opinion of this court, important anomaly which we cannot be unmindful is that whereas the entire tax exempt income is Rs. 48,90,000/- the disallowance ultimately directed works out to nearly 110% of that sum, i.e., Rs. 52,56,197/-. By no stretch of imagination can Section 14A or Rule 8D be interpreted so as to mean that the entire ta....