Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (11) TMI 629 - AT - Income TaxRevision u/s 263 by CIT - Disallowance u/s 14A - HELD THAT:- Hon'ble Delhi High Court in the case of M/s. Holcim India P. Ltd [2014 (9) TMI 434 - DELHI HIGH COURT] held that no disallowance can be made u/s.14A if there is no exempt income in the relevant year. PCIT has not disputed the fact that the assessee has not earned any exempt income. Hence, in view of the judicial pronouncement, we hereby hold that the order the AO is not prejudicial to the interest of the revenue. Hence, we hereby hold that the order passed by the ld. PCIT u/s. 263 is legally not sustainable. Decided in favour of assessee.
|