No section 14A Disallowance if no Exempt Income received during the year under consideration

Addl. CIT Vs TV Today Network Ltd. (ITAT Delhi) The Ground in respect of deleting disallowance of Rs. 56,20,737/- u/s 14A of the Act on the ground that disallowance u/s 14A cannot exceed exempt income. The issue involved in Ground No. 2 is also decided in favour of the assessee in ITA No. 7277/Del/2018 for Assessment Year 2013-14. The facts of the case are that the A.O invoking provision of Section 14A of the Act, made disallowance of Rs. 56,27,37/- while making the said disallowance the Ld. A.O has recorded clear finding that “the controversy raised in the instant case was the assessee had ...