If assessee not earned exempted income, there cannot be section 14A disallowance

Vertex Securities Ltd Vs ITO (ITAT Cochin)

The assessee has made an investment in equity shares of Rs.5,84,10,100/-. The dividend from such investment is exempted from the tax. Accordingly, AO computed the disallowance u/s 14A of the Act at Rs.11,84,111/-. The same was confirmed by the Ld. CIT(A). Before us, Ld. A.R. submitted that assessee being not exempted income as such section 14A r.w. Rule 8D of the Income Tax Rules cannot be applied to the assessee’s case. In our opinion, whether the assessee has earned exempt incom

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