Section 14A r.w. Rule 8D cannot be interpreted to mean disallowance of entire tax exempt income

Pest Control India Pvt Ltd vs. DCIT (ITAT Mumbai)

By no stretch of imagination can Section 14A or Rule 8D be interpreted so as to mean that entire tax exempt income is to be disallowed

The Hon’ble Delhi High Court in the case of Joint Investment Private Limited in ITA.No. 117/15 dated 25.02.2015 held that by no stretch of imagination can section 14A or Rule 8D be interpreted so as to mean that entire tax exempt income is to be disallowed.

Disallowance under Section 14A or Rule 8D cannot exceed the exempt income

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