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| The Tax Publishers2020 TaxPub(DT) 1537 (Mum-Trib) INCOME TAX ACT, 1961
Section 14A Rule 8D
Where assessee did not earn any exempt income during year under consideration, the disallowance made under section 14A was restricted to suo-moto disallowance offered by the assessee.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income -
Assessee-company made suo-moto disallowance under section 14A. AO invoking provisions of rule 8D, made further disallowance over and above the disallowance made by the assessee. Assessee submitted that it did not earn any exempt income during the year; the disallowance made by the AO was not sustainable. Held: Since assessee did not earn any exempt income during year under consideration, the AO was directed to restrict the disallowance under section 14A to suo-moto disallowance offered by the assessee.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 5
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