No disallowance U/s 14A if there is no exempt income

Counsel for the assessee submits that assessee has not received any exempt income and in the absence of the assessee receiving any exempt income, there is no justification in deriving expenses attributable for earning income which is not received by the assessee. He places reliance on the recent decision of the Hon’ble Allahabad High Court in the case of CIT Vs. M/s. Sivam Motors Pvt.Ltd. in I.T. Appeal No.88 of 2014 dated 5.5.2014 for the assessment year 2008-09, the decision of the Hon’ble Gujarat High Court in the case of CIT Vs. Corrtech Energy Pvt. Ltd. in Tax Appeal No.239 of 2014 da...