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| The Tax Publishers2020 TaxPub(DT) 3226 (Chd-Trib) INCOME TAX ACT, 1961
Section 14A Rule 8D
Where assessee did not claim any exempt income during the year, there was no question of making disallowance under section 14A read with rule 8D and hence, the disallowance made under section 14A read with rule 8D was liable to be deleted.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income claimed by assessee -
AO made disallowance by invoking provisions of section 14A read with rule 8D. Assessee contended that since it did not claim any exempt income during the year, there was requirement to make disallowance under section 14A read with rule 8D.Held: It was an admitted position that assessee did not claim any exempt income during the year, thus, there was no question of making disallowance under section 14A read with rule 8D. Hence, the disallowance made under section 14A read with rule 8D was deleted.
REFERRED : CIT v. Winsome Textile Industries Ltd. (2009) 319 ITR 204 (P&H) : 2009 TaxPub(DT) 2012 (P&H-HC).
FAVOUR : In assessee's favour.
A.Y. : 2013-14
IN THE ITAT, CHANDIGARH BENCH
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