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2018 (8) TMI 671 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - expenditure towards exempted income i.e. Dividend income - revenue contended that assessee cannot earn dividend income without systematic management and that dividend income can be earned by incurring no or nominal expenditure - Assessee contended that it has not received any dividend or exempted income during the relevant year - Held that:- The learned CIT(A) has given relief to the assessee based upon the proposition that if no exempt income has been received during the relevant year, no disallowance can be made u/s. 14A of the Act. If no exempt income is received during the previous year relevant to the impugned assessment year, no disallowance of expenditure u/s 14A of the Act of 1961 is warranted. - Decided against the revenue.
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