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In the result, this appeal filed by Revenue in ITA
Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am
disallowance is applicable, even in cases where no exempt income was earned during the year, but there is a possibility of earning the exempt income and the circular is not overriding the express provisions of Section 14A read with Rule 8D. 7. Learned CIT(A) ought to have considered that in the case of CIT v. Walfort Share &Stock Brokers