Disallowance u/s. 14A cannot be more than exempt income

DCIT Vs PTC India Financial Services Ltd. (ITAT Delhi) ITAT Delhi held that disallowance under section 14A of the Income Tax Act cannot exceed the exempt income. Facts- The assessee is a Non-Banking Financial Company. AO made disallowances under section 14A of the Income Tax Act. CIT(A) deleted the partly addition made on account of disallowance u/s. 14A of the Income Tax Act. Being aggrieved, both revenue and assessee has preferred the present appeal. Conclusion- Held that AO has mechanically applied the formula given in Rule 8D, hence he found that AO has computed the disallowance which is f...