Disallowance u/s. 14A read with rule 8D cannot exceed exempt income

DCIT Vs Sahyadri Agencies Limited (ITAT Mumbai)

ITAT Mumbai held that the disallowance under section 14A of the Income Tax Act read with rule 8D cannot exceed the exempt income earned by the assessee during the relevant previous year. Accordingly, no further disallowance u/s. 14A is called for.

Facts- Post scrutiny assessment, AO passed the assessment order dated 01.09.2021 by disallowing the deduction claimed by the assessee under section 36(1)(iii) of the Act in respect of interest of Rs.18,05,18,055/- on borrowed funds. Also, a further disallowance of Rs

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