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The Tax PublishersITA No. 1121/Ahd/2015
2020 TaxPub(DT) 2310 (Ahd-Trib)INCOME TAX ACT, 1961
Section 14A
In the absence of exempt income earned by assessee during the year, there could not be any disallowance under section 14A.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income received during the year -
AO noticed investments in assessee's balance sheet and made disallowance under section 14A. Assessee's case was that no exempt inome was received during the year.Held: In the absence of exempt income earned by assessee during the year, there could not be any disallowance under section 14A.
Followed:S.R. Koshti v. CIT (2005) 276 ITR 165 (Guj) : 2005 TaxPub(DT) 1136 (Guj-HC) and CIT v. Shelly Products, (2003) 261 ITR 367 (SC) : 2003 TaxPub(DT) 1281 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
IN THE ITAT, AHMEDABAD BENCH
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