TMI Blog2020 (2) TMI 825X X X X Extracts X X X X X X X X Extracts X X X X ..... are similar to that of the assessment years 2010-11, 2011-12 and 2012-13, this Tribunal is of the considered opinion that the claim of expenditure towards interest cannot be allowed as revenue expenditure. Therefore the order of both the authorities below is confirmed. Disallowance u/s.14A - Admittedly the assessee had not earned any exempt income in the year under consideration. The Madras High Court in the case of M/s. Redington (India) Ltd. [ 2017 (1) TMI 318 - MADRAS HIGH COURT] found that unless there was an exempted income, there cannot be any disallowance U/s.14A of the Act. In view of the judgment of the Madras High Court in M/s. Redington (India) Ltd., this Tribunal is of the considered opinion that there cannot be any disall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . In view of the decision of this Tribunal for the assessment years 2010-11 and 2012-13 in ITA Nos.2084, 2085 2086/Chny/2016 dated 27.06.2018, the grounds of appeal may be decided against the assessee. Coming to the disallowance made U/s.14A of the Income Tax Act, 1961 (in short the Act ), the Ld. Representative for the assessee submitted that there was no dividend income earned by the assessee during these years under consideration. Therefore, in view of the judgment of the Madras High Court in the case of M/s. Redington (India) Ltd., Vs. Addl.CIT (2017) 392 ITR 633, there cannot be any disallowance U/s.14A of the Act. 4. We heard Shri Pavithran Kumar, the Ld. Departmental Representative also. According to the Ld.DR, interest expendi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dia) Ltd., discussed this issue elaborately and found that unless there was an exempted income, there cannot be any disallowance U/s.14A of the Act. In view of the judgment of the Madras High Court in M/s. Redington (India) Ltd., this Tribunal is of the considered opinion that there cannot be any disallowance. The judgment referred by the CIT(A) is not relevant to the facts of the present case. The judgment of Madras High Court is binding on all authorities in the State of Tamil Nadu and Pondicherry including this Tribunal. Therefore this disallowance made by the Assessing Officer U/s.14A of the Act is deleted. 6. In the result, both the appeals filed by the assessee are partly allowed. Order pronounced in the court on 3rd January, 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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