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| The Tax Publishers2019 TaxPub(DT) 4525 (Mum-Trib) INCOME TAX ACT, 1961
Section 14A
Since assessee had not earned any exempt income during the relevant year, no disallowance under section 14A was permissible.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income during the year -
AO noticed investments in mutual fund units in assessee's balance-sheet and accordingly invoked section 14A read with rule 8D leading to disallowance. Assessee's case was that no exempt income was earned during the year under consideration.Held: Since assessee had not earned any exempt income during the relevant year, no disallowance under section 14A was permissible.
Followed:Cheminvest Ltd. v. CIT [ITA No. 749 of 2014] (Delhi High Court) and Asstt. CIT v. Ballarpur Industries Ltd. [ITA No. 51 of 2016] (Bombay High Court].
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 37(1)
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