| The Tax Publishers2019 TaxPub(DT) 6702 (Mum-Trib) : (2020) 180 ITD 0844 INCOME TAX ACT, 1961
Section 14A Rule 8D
Where assessee did not earn any exempt income during year under consideration, no disallowance under section 14A read with rule 8D could be made.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income -
AO made disallowance under section 14A read with rule 8D. Assessee contended that it did not earn any exempt income during year under consideration, therefore, no disallowance under section 14A read with rule 8D could be made. Held: Since assessee did not earn any exempt income during year under consideration, no disallowance under section 14A read with rule 8D could be made.
Relied:CIT v. Chettinad Logistics Pvt. Ltd., (2018) 98 taxmann.com 250 (SC): 2018 TaxPub(DT) 4126 (SC) DCIT v. L&T Power Development Ltd., ITA No. 874/Mum. /2017, 9-8-2018 DCIT v. Future Market Networks Ltd., ITA No. 5781/Mum. /2016, etc., dated 3-10-2018 Tejaskiran Pharmachem Industries Pvt. Ltd. v. DCIT, ITA No. 3307/Mum. /2014, dated 13-12-2017]: 2018 TaxPub(DT) 0524 (Mum-Trib) Sajjan India Ltd. v. ACIT, (2018) 89 taxmann.com 21 (Mum-Trib.): 2018 TaxPub(DT) 0084 (Mum-Trib) Chand N. Bhojawani v. DCIT, ITA No. 272/Mum. /2015 etc., dated 28-7-2017 and Techprocess Payment Services Ltd. v. DCIT, ITA No. 8547/Mum. /2011, dated 12-10-2018
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 24(b)
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