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The 1st issue raised by the assessee is that the learned CIT (A) erred in part confirming the disallowance made by the AO for Rs. 87,544/- under the provisions of section 14A read with rule 8D of Income Tax Rule.

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Section 14A of the Income-tax Act, 1961—Expenditure incurred in relation to earning exempt income - If the assessee can demonstrate availability of surplus interest free funds for making investment generating tax free income, disallowance under Section 14A would not be justified. - GUJARAT STATE ENERGY GENERATION LTD. V/s ACIT - [2020] 183 ITD 590 (ITAT-AHMEDABAD)