If dividend is not received, disallowance u/s 14A cannot be made

CA Sandeep Kanoi In the case of ACIT Vs. M/s. Bharat Hotels Ltd. Hon’ble ITAT delhi held that in case the dividend income is not received by an assessee, the disallowance u/s 14A cannot be made. In further held that  Once the assessee has been found to have made a business investment by way, of shares in related line of business, the said investment though held by way of shares in the said company cannot be subjected to disallowance under section 14A of the Act, which in any case is relatable to disallowance of the expenditure out of the exempt income earned by the assessee, by way of i...