TMI Blog2017 (9) TMI 1711X X X X Extracts X X X X X X X X Extracts X X X X ..... ch exempt income in the impugned assessment year. We therefore quote hon’ble jurisdictional high court’s decision in CIT vs. Corrtech Energy P. Ltd [2014 (3) TMI 856 - GUJARAT HIGH COURT] holding that Section 14A read with computation provision enshrined in Rule 8D does not apply in absence of any exempt income in relevant previous year. We therefore quote the above judicial precedent to delete th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sion in Kanoi paper & Industries Ltd. vs. ACIT [2001 (5) TMI 139 - ITAT CALCUTTA-E] that the relevant date in such case is that of month of the actual payment of wages/salaries. We therefore rely on the above co-ordinate bench decision and direct the Assessing Officer to delete the impugned disallowance as well. - Assessee appeal allowed - ITA No. 940/Ahd/2015 - - - Dated:- 22-9-2017 - SHRI S. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diture in earning its exempt dividend income. The case file however indicates that the assessee has not derived any such exempt income in the impugned assessment year. We therefore quote hon ble jurisdictional high court s decision in CIT vs. Corrtech Energy P. Ltd, reported in [2015] 372 ITR 97 (Guj.) holding that Section 14A read with computation provision enshrined in Rule 8D does not apply in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cating it to have paid above employees PF/ESI contributions on 22.05.2009 and 28.05.2009 as against the due dates thereof following on 20.06.2009. The Revenue fails to dispute this factual position. We therefore quote this tribunal s co-ordinate bench decision in Kanoi paper Industries Ltd. vs. ACIT 75 TTJ 448 that the relevant date in such case is that of month of the actual payment of wages/s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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