2022 (11) TMI 1572

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....ujahid, Jr. Standing Counsel and Mr. Nikhil Jain, Advocate For the Respondent : None ORDER CM APPL.50604/2022 Keeping in view the averments in the application, the delay in filing the appeal is condoned. Accordingly, the application stands disposed of. ITA 484/2022 Present Income Tax Appeal has been filed challenging the Order dated 11th May, 2022 passed by the Income Tax Appe....

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....the paper book reveals that the Authorities below have given concurrent findings of fact that the assessee did not earn any dividend income during the year under consideration. The relevant extract of the ITAT order is reproduced hereinbelow:- "8. We have heard the Learned DR and perused the material on record. The issue in the present ground is with respect to the disallowance u/s 14A r.....

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....s covered by the Division Bench judgment in Cheminvest Ltd. vs. CIT, [2015] 61 Taxmann.com 118 (Delhi), wherein it has been held that the expression 'does not form part of the total income' in Section 14A of the Act means that there should be an actual receipt of income which is not includable in the total income during the relevant previous year for the purpose of disallowing any expendit....