Section 14A disallowance not warranted in absence of tax-free income

PCIT Vs Greenland Infracon P. Ltd. (Gujarat High Court)

Section 14A of the Act can be invoked only if the assessee seeks to square off the expenditure against the income which does not form part of the total income under the Act, and in such circumstances, Section 14A of the Act could not have been invoked, more particularly, when no exempt income was earned in the relevant assessment years.

FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT