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| The Tax Publishers2019 TaxPub(DT) 4692 (Bom-HC) : (2019) 417 ITR 0103 : (2019) 309 CTR 0032 : (2019) 264 TAXMAN 0042 INCOME TAX ACT, 1961
Section 14A
As assessee had not earned any exempt income during the year under consideration, therefore, disallowance of expenditure under section 14A would not be permissible.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income earned by assessee during the year -
AO noticed investments in assessee's balance-sheet and accordingly invoking section 14A worked out disallowance. Assessee's case was that no exempt income was earned during the year.Held: As assessee had not earned any exempt income during the year under consideration, therefore, disallowance of expenditure under section 14A would not be permissible.
Followed:Cheminvest Ltd. v. CIT (2015) 378 ITR 33 (Del) : 2015 TaxPub(DT) 3520 (Del-HC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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