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Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar
section 14A of the Act is without jurisdiction and bad in law and calls for being deleted in toto, on this preliminary ground itself. Without prejudice, the disallowance, if any, should be restricted to a reasonable percentage of exempt income earned during the year. Reliance in this regard is placed on the decision of the Hon’ble ITAT, Delhi Bench