Disallowance U/s.14A cannot be made if assessee has not incurred & claimed any expenditure against exempt income

In our considered opinion. for making any dis allowance u/s. 14A is to firstly examine the assessee’s claim of having incurred some expenditure or no expenditure in relation to exempt income. If the AO gets satisfied with the same then there is no need to compute dis allowance as per Rule 8D. It is only when the AO is not satisfied with the correctness of the claim of the assessee in respect of such expenditure or no expenditure having been incurred in relation to exempt income that the mandate of Rule 8D will operate. In the instant case the authorities below have directly gone to the s...