TMI Blog2019 (6) TMI 599X X X X Extracts X X X X X X X X Extracts X X X X ..... ourts. Even the different Hon'ble High Courts of the country have been unanimous to hold that no disallowance is attracted u/s 14A in case the assessee has not earned any income not forming part of the total income See WINSOME TEXTILE INDUSTRIES LTD. [ 2009 (8) TMI 220 - PUNJAB AND HARYANA HIGH COURT], M/S LAKHANI MARKETING INCL [ 2014 (7) TMI 44 - PUNJAB AND HARYANA HIGH COURT] and CHEMINV ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ule 8D of the Income Tax Rules in respect of the expenditure incurred for earing of tax exempt income. 2. At the outset, it was the plea of the Ld. Counsel for the assessee that all the investments in the subsidiary companies were made in the earlier years out of own funds and that the assessee had not earned any exempt income from such investments as is evident from the profit and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... factual findings given by the Ld. CIT(A). 4. We have considered the rival submissions. From the record it is an undisputed fact that the assessee has not earned tax exempt income during the year. We find that the issue is now squarely covered by the various decisions of the Hon'ble High Courts. Even the different Hon'ble High Courts of the country have been unanimous to hol ..... X X X X Extracts X X X X X X X X Extracts X X X X
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