Disallowance u/s 14A was invalid in absence of Exempt Income

DCIT Vs John Deere India Private Limited (ITAT Pune)

Conclusion: Disallowance under Section 14A  was invalid due to the absence of exempt income and no material or evidence was submitted by the AO to show that any expenditure had been incurred on the activity, which had resulted in exempt income.

Held: Assessee-company was involved in manufacturing tractors, agricultural equipment, and spare parts, also operated a technology center providing IT and engineering services to Deer Associates. It filed its income tax return declaring a total inc

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