2015 (6) TMI 1168

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..... to compute disallowance u/s 14A read with Rule 8D. In the absence of any exempt income, there can be no disallowance u/s 14A. Hon’ble jurisdictional High Court in CIT vs. Holcim India Pvt. Ltd. (2014 (9) TMI 434 - DELHI HIGH COURT) has held that no disallowance u/s 14A can be made in the absence of any exempt income - Decided in favour of assessee - ITA No.684/Del/2014 - - - Dated:- 19-6-2015 - .....

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..... plus funds of its own and the investments in securities were made out of such surplus funds. Not convinced, the AO invoked the provisions of section 14A and, accordingly, made disallowance to the tune of ₹ 45,46,631/-. The ld. CIT(A) upheld the impugned order. The assessee is aggrieved against the addition. 3. I have heard the rival submissions and perused the relevant material available .....

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