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| The Tax Publishers2023 TaxPub(DT) 531 (Del-Trib) INCOME TAX ACT, 1961
Section 14A
As there was no exempt income, then there could be no disallowance under section 14A. Suo moto disallowance could not have been made the basis for restricting the relief once it was withdrawn during assessment proceedings by assessee company.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income earned during the year - CIT(A) upheld disallowance to the extent of amount suo moto disallowed by AO
Assessee earned no exempt income during the year, however, CIT(A) restricted disallowance under section 14A to the extent of suo moto disallowance offered by assessee. Held: As there was no exempt income then there could be no disallowance under section 14A. Suo moto disallowance could not have been made the basis for restricting the relief once it was withdrawn during assessment proceedings by assessee-company.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2015-16
INCOME TAX ACT, 1961
Section 251(1)
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