If no expenditure has been incurred to exempt income no disallowance under section 14A can be made

In CIT vs. Hero Cycles 323 ITR 518 (P&H) it was held that dis allowance u/s 14A required finding of incurring of expenditure and where it was found that for earning exempted income no expenditure had been incurred, disallowance u/s 14A could not stand. On the other hand, in Godrej Boyce Mfg. Co 328 ITR 81 (Bom) i

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