No Disallowance u/s 14A Without Exempt Income – ₹43.23 Cr Addition Deleted: ITAT Mumbai

Shri Hari Trust Vs ACIT (ITAT Mumbai) No disallowance u/s 14A without exempt income – Even suo-moto disallowance withdrawable; additions of ₹43.23 Cr deleted – ITAT Mumbai In Shri Hari Trust vs ACIT (A.Y. 2016-17), the AO invoked section 14A r.w. Rule 8D and made total disallowance of ₹43.23 crore, including additional disallowance of ₹24.94 crore over and above assessee’s suo-moto disallowance of ₹18.28 crore. The assessee argued that no exempt income was earned during the year and the suo-moto disallowance itself was wrongly made due to incorrect advice. The ITAT accepted that ...