The Tax Publishers2019 TaxPub(DT) 5693 (Del-Trib)

INCOME TAX ACT, 1961

Section 14A

In the absence of any exempt income earned by assessee during the relevant year, disallowance under section 14A of any amount was not permissible.

Disallowance under section 14A - Expenditure against exempt income - No exempt income earned by assessee - Validity of

Assessee assailed disallowance made under section 14A contending that no exempt income was earned by it during the relevant year. Held: In the instant case, it was undisputed that assessee had not received any exempt income during the year under consideration. Therefore, in the absence of any exempt income, disallowance under section 14A of any amount was not permissible.

Followed:Cheminvest Ltd. v. CIT (2015) 378 ITR 33 (Del-HC) : 2015 TaxPub(DT) 3520 (Del-HC)

REFERRED :

FAVOUR : In assessee's favour

A.Y. :



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