Dismissing the appeal of the assessee against the revision order of the Commissioner of Income-tax , the Tribunal held that , Disallowance has to be made even if the assessee has not earned any tax free income on the investment. Tribunal held that Cheminvest Ltd v. CIT (2015) 378 ITR 33 (Delhi) (HC ) is not binding on the assessee as it is a non -jurisdictional High Court .CBDT ‘s Circular 5/2/2014 is accordance with Godrej & Boycee Manufacturing .Co Ltd v.Dy.CIT (2017 ) 394 ITR 449 (SC) & Maxopp Investment Ltd v.CIT ( 2018) 402 ITR 640 (SC) (ITA No 218 (Asr) 2017 dt.12-04 02018 )( AY. 2012-13)