S. 14A cannot be invoked if no regular activity in respect of Investment

ITAT Delhi Held that  Section 14A of Income Tax Act,1961 cannot be invoked, where no regular activities were undertaken by the Assessee in respect of the investments to earn exempt income and no change in the investments during the year? Brief Facts of the Case: The assessee company is engaged in the business of transmission of power, telecom and consultancy. It filed its return of income on 22.09.2009 showing NIL income. MAT was paid on book profit under Section 115JB of the Income Tax Act, 1961. The return was revised by the company to claim the credit of TDS not claimed in the original ret...