The Tax Publishers2021 TaxPub(DT) 4087 (Del-Trib)

INCOME TAX ACT, 1961

Section 14A

In absence of any exempt or dividend income received during the year under consideration, no disallownace could be made under section 14A read with rule 8D.

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

Assessee challenged disallowance made under section 14A read with rule 8D on the ground that no exempt income was earned during the year.Held: As assessee had not received any exempt income during the year, no disallowance could be made under section 14A.

Followed:Chiminvest Ltd. v. CIT (2015) 378 ITR 33 (Del-HC), and CIT v. Chettinad Logistics (P) Ltd. (2018) 95 Taxmann.com 250 (SC) : 2018 TaxPub(DT) 4126 (SC).

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2011-12


INCOME TAX ACT, 1961

Section 2(22)(e)

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