2014 (3) TMI 856 - GUJARAT HIGH COURT

Disallowance of interest expenses u/s 14A of the Act r.w. Rule 8D of the Rules – Held that:- The decision in CIT vs. Winsome Textile Industries Ltd. [2009 (8) TMI 220 - PUNJAB AND HARYANA HIGH COURT] followed - the assessee did not make any claim for exemption – thus, section 14A could have no application - subsection( 1) of section 14A provides that for the purpose of computing total income under chapter IV of the Act, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total income under the Act - the tribunal has recorded the finding of fact that the assessee did not make any claim for exemption of any income from payment of tax - It was on this basis that the tribunal held that disallowance under section 14A of the Act could not be made – no question of law arises for consideration – Decided against Revenue.