No section 14A Disallowance if There is No Exempt Income

Tata Sky Limited Vs. CIT (ITAT Mumbai) The issue under consideration is whether the disallowance of expenditure under section 14A is justified if there is no exempt income? In the instant case, the assessee has invested in various investments which, yield exempt income. Further, the assessee has not made suo moto disallowance of expenditure incurred in relation to exempt income u/s 14A of the IT Act, 1961. The AO has disallowed interest expenses and other expenses by invoking Rule 8D(2)(ii)and (iii) on the ground that although the assessee has debited huge interest expenses and other administr...