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| The Tax Publishers2021 TaxPub(DT) 2376 (Chen-Trib) : (2021) 188 ITD 0780 : (2022) 096 ITR (Trib) 0402 INCOME TAX ACT, 1961
Section 14A
As no exempt income was earned by assessee in the relevant assessment year, no disallowance could be made under section 14A.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income earned during the year -
AO noticed that assessee had made huge investments in shares and securities, but did not make suo moto disallowance of any expenses relatable to exempt income and hence. AO invoked rule 8D and computed disallowance under section 14A. Assessee contended that there was no exempt income earned for the relevant assessment year. Held: As no exempt income was earned by assessee in the relevant assessment year, no disallowance could be made under section 14A.
Followed:Redington India Ltd. v. Addl. CIT (2016) 97 CCH 219 (Mad) : 2017 TaxPub(DT) 345 (Mad-HC). Supported by:CIT v. Chettinad Logistics Pvt. Ltd. (2018) 95 taxmann.com 250(SC) : 2018 TaxPub(DT) 4126 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 32(1)
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