Section 14A Disallowance cannot exceed Exempt Income

Century Real Estate Holdings Pvt. Ltd. Vs ACIT (ITAT Bangalore) The issue under consideration is whether the disallowance u/s 14A can exceed exempt income? ITAT states that, the assessee argued that dis-allowance under section 14A cannot exceed amount of exempt income. ITAT find that the Hon’ble Delhi High Court in the case of Joint Investments (P.) Ltd. (supra) held that the window for disallowance is indicated in section 14A and is only to the extent of disallowing expenditure incurred by the assessee in relation to tax exempt income. This proportion or portion of the tax exempt income sur...