2017 (11) TMI 126

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....017 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 of income not forming pan of the Total income of t....

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....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 tax exempt income is to be disallowed. The window for disall....