No Section 14A addition if no exempt income earned in relevant year

DCIT Vs Asset Auto India Pvt. Ltd (ITAT Mumbai)

The fact remains that no exempt income was earned by the assessee during the year under consideration. The Ld. CIT(A) has rightly followed the judgement of the Hon’ble Delhi High Court in Holcim India (P.) Ltd (supra).; IL & FS Energy Development Company Ltd (supra), where it has been held that there can be no disallowance under section 14A in the absence of exempt income.

The Ld. CIT(A) has rightly referred to the SLP dismissed by the Hon’ble Supreme Court again

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