2026 (5) TMI 1189

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.... the Assessee : Shri P.D. Shah, AR For the Revenue : Shri Rameshwar P. Meena, Sr.DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals) [ADDL/JCT(A)-4 BENGALURU, [hereinafter referred to as 'CIT(A)'] dated 19/08/2025 passed u/s. 250 of the Income Tax Act, 1961 (hereinafter re....

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....s submitted that since the assessee did not earn any tax exempt income during the year under consideration, therefore, no disallowance is warranted u/s 14A of the Act. He in this respect has relied upon the following case laws: 1. Cheminvest Ltd. vs. CIT 378 ITR 33 (Del); 2. CIT vs. M/s. Holcim India Pvt. Ltd. in ITA No. 486/2014 and ITA No. 299/2014; Judgment dated 05-09-2014 ....

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....art of the total income under this Act.] ************************ *********************** [Explanation.--For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained in this Act, the provisions of this section shall apply and shall be deemed to have always applied in a case where the income, not forming part of the total income under this Act, ....