| |
| The Tax Publishers2020 TaxPub(DT) 2537 (Chen-Trib) : (2020) 183 ITD 0782 : (2020) 083 ITR (Trib) 0530 INCOME TAX ACT, 1961
Section 14A
No disallowance of expenditure is warranted by invoking provisions of section 14A when no exempt income is received by the taxpayer during year under consideration.
|
Disallowance under section 14A - Expenditure against income - No dividend income earned during relevant year by assessee -
Revenue challenged order of CIT(A) deleting disallowance made under section 14A read with rule 8D by holding that disallowance cannot be made in the absence of exempt income earned during a year. Held: Delhi High Court in case of Cheminvest Ltd. v. CIT had held that no disallowance of expenditure is warranted by invoking provisions of section 14A when no exempt income is received by the taxpayer during year under consideration. Thus, on that short reasoning alone grounds raised by revenue were dismissed.
Followed:Cheminvest Ltd. v. CIT (2015) 378 ITR 33 (Delhi) : 2015 TaxPub(DT) 3520 (Del-HC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 36(1)(viii)
 SUBSCRIBE FOR FULL CONTENT
|