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Case Law Details

Case Name : JCIT Vs Reliance Life Sciences Pvt. Ltd. (ITAT Mumbai)
Appeal Number : ITA No.2924/Mum./2019
Date of Judgement/Order : 08/09/2021
Related Assessment Year : 2014-15
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JCIT Vs Reliance Life Sciences Pvt. Ltd. (ITAT Mumbai)

We agree with the submissions of the Ld. Counsel for the assessee that since assessee has not earned any exempt income and therefore no disallowance is warranted u/s. 14A of the Act. In the case of Joint Investments Pvt. Ltd. v. CIT [372 ITR 694] the Hon’ble Delhi High Court held that the disallowance u/s. 14A of the Act should not exceed the exempt income. The Revenue filed SLP against this decision and the Hon’ble Supreme Court dismissed the SLP filed by the Revenue. Similar view has been taken by the Hon’ble Delhi High Court in the case of Cheminvest Limited v. CIT [378 ITR 33]

Disallowance under section 14A

FULL TEXT OF THE ORDER OF ITAT MUMBAI

The captioned appeal has been filed by the Revenue challenging the impugned order dated 27th February 2019, passed by the learned Commissioner (Appeals)–57, Mumbai, pertaining to the assessment year 2014–15.

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