No section 14A disallowance if no exempt income is received during relevant year

ACIT Vs Him Urja Pvt. Ltd. (ITAT Delhi)

The assessee has also submitted before the Ld. CIT(A) that as there was no exempt income earned by assessee during the relevant previous year, no disallowance under section 14A could be made. The assessee relied upon Judgment of the Hon’ble Delhi High Court in the case of Chemnivest Ltd., vs., CIT-IV 61 taxmann.com 118 (Del.).

After considering the rival submissions, we are of the view that the Departmental appeal has no merit. It is an undisputed fact that assessee has not re

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