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13. [2016] 161 ITD 217 (Pune Trib.) Quality Industries vs. JCIT A.Y.: 2010-11 Date of Order: 9th September, 2016.

C. N. Vaze
Shailesh Kamdar
Jagdish T. Punjabi
Bhadresh Doshi
Chartered Accountants

Section 14A – When an assessee, a partnership firm, earns tax free income and disallowance u/s. 14A (r.w. Rule 8D) is to be computed then interest paid, towards the use of partner's capital, by the assessee to the partners is not amenable to section 14A in the hands of partnership firm.


The assessee, a partnership firm, engaged in the business of manufacturing of chemicals etc., had during the relevant assessment year earned tax free dividend income from investment in mutual funds which was claimed as exempt income u/s. 10(35) of the Act.

The AO next observed that investment in mutual funds...

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