No Section 14A Disallowance When Exempt Income Is Minimal or Absent: ITAT Delhi

DCIT Vs Outsourcepartners International Pvt. Ltd (ITAT Delhi) No Section 14A Disallowance Where Growth Funds Yield Only Taxable Gains The Delhi ITAT dismissed both the Revenue’s and the assessee’s cross appeals in a case involving disallowance under Section 14A read with Rule 8D. The Tribunal upheld the CIT(A)’s deletion of ₹2.13 crore disallowance, holding that the computation mechanism under Rule 8D failed on facts. The assessee’s investments were mainly in mutual fund Growth Plans, which yielded only appreciation taxable as capital gains and were not capable of earning exempt inco...