The Tax Publishers2019 TaxPub(DT) 5583 (Bang-Trib)

INCOME TAX ACT, 1961

Section 14A

In view of undisputed fact that assessee had not earned any exempt income during year under consideration, no disallowance could be made under section 14A.

Disallowance under section 14A - Expenditure against exempt income - No exempt income earned during the year -

AO noticed investments in assessee's balance-sheet and accordingly invoked section 14A and worked out disallowance. Assessee's case was that no exempt income was earned during the year.Held: In view of undisputed fact that assessee had not earned any exempt income during year under consideration, no disallowance could be made under section 14A.

Followed and Supported by:Cheminvest Ltd. (2015) 378 ITR 33 (Del) : 2015 TaxPub(Dt) 3520 (Del-HC).

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2012-13



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