|The Tax Publishers2021 TaxPub(DT) 0718 (Karn-HC) : (2021) 434 ITR 0154
INCOME TAX ACT, 1961
Since no exempt income has accrued to the assessee, therefore, the provisions of section 14A do not apply to the fact situation of the case.
Disallowance under section 14A - Expenditure against exempt income - No exempt income accrued to assessee -
AO made disallowance under section 14A on the ground that assessee had not determined the expenditure incurred in relation to exempt income. Held: It was found that no exempt income was earned by assessee. In case of Biocon Ltd. [ITA. No. 416 of 2014, dt. 12-1-2021] it was held that that if no exempt income has accrued to the assessee the provisions of section 14A do not apply. Thus, following the same, no disallowance under section 14A could be made.
Followed:[Biocon Ltd.[I.T.A. NO. 416 OF 2014, dt. 12-1-2021].
FAVOUR : In favour of assessee.
IN THE KARNATAKA HIGH COURT
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