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2025 (4) TMI 2202

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....venue : Shri Subramanian S, JCIT(DR) ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the NFAC, Delhi dated 18/06/2024 vide DIN No. ITBA/NFAC/S/ 250/2024-25/1065707293(1) for the assessment year 2016-17. 2. In the present case, the AO during the assessment proceedings found that the assessee has earned exempted income but th....

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....ncome earned by the assessee. 6. On the other hand, the learned Departmental Representative (DR) argued that the computation under Rule 8D was correctly applied by the AO as per the provisions of the Act. However, it was also fairly admitted that the recent judicial pronouncements have restricted such disallowances to the extent of exempt income. 7. We have heard the submissions of both part....

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....Har.) decided on 27.02.2017 wherein after considering the relevant provision and the case law on the point, it was recorded as under:- "After hearing learned counsel for the parties, we notice that the issue on merits has been decided in favour of the assessee in State Bank of Patiala's case (supra) [(2017) 78 Taxman.com 3]. The amount of disallowance under Section 14A was restricted ....