No Exempt Income, No 14A: ITAT Delhi Deletes ₹1.24 Cr Disallowance 

Pure Home & Living Private Limited Vs ACIT (ITAT Delhi) In this appeal, Assessee challenged the disallowance of ₹1,24,23,882 made u/s 14A r.w. Rule 8D despite earning no exempt income during AY 2017-18. After condoning the 99-day delay-holding that pre-occupation of the General Manager with ITR deadlines constituted reasonable cause-Tribunal examined the merits. Tribunal noted that Assessee had earned no exempt income, & in its own earlier year (DLF Brands Ltd., ITA 4151/Del/2017), the same issue had already been decided in Assessee’s favour. Tribunal also relied on binding precede...