| COURT: | Delhi High Court |
| CORAM: | R. K. Gauba J, Ravindra Bhat J |
| SECTION(S): | 14A, Rule 8D |
| GENRE: | Domestic Tax |
| CATCH WORDS: | Disallowance u/s 14 & Rule 8D, exempt income |
| COUNSEL: | Piyush Kaushik |
| DATE: | February 25, 2015 (Date of pronouncement) |
| DATE: | March 9, 2015 (Date of publication) |
| AY: | 2009-10 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| S. 14A & Rule 8D cannot be interpreted to mean that the entire tax exempt income can be disallowed | |
By no stretch of imagination can Section 14A or Rule 8D be interpreted so as to mean that the entire tax exempt income is to be disallowed. The window for disallowance is indicated in Section 14A, and is only to the extent of disallowing expenditure “incurred by the assessee in relation to the tax exempt income”. This proportion or portion of the tax exempt income surely cannot swallow the entire amount as has happened in this case
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